This Privacy Statement applies to our collection, use and disclosure of information about you on Sulcus Learning Inc. ("Sulcus", "we", "us", or "our") websites ("Websites"), mobile applications ("Apps") and social medial platforms (together "Services") and does not apply to third party websites or apps accessible via hyperlinks from this Website. Please be sure to read this entire Privacy Statement before using our Services. By using our Services, you agree to the terms of this Privacy Statement.
SULCUS may update this Privacy Statement from time to time. If we update this Privacy Statement, we will use reasonable electronic efforts to advise you of the change, which may include posting a notice of the change on our Services, or we may send you an electronic notification of the change. If we electronically notify you by email, we will provide these electronic messages to your last known or provided electronic address. You are responsible for reviewing communications we send to those addresses and to keep those addresses current. Use of our Services after our notice of a change in the Privacy Statement constitutes acceptance of the terms and changes in the updated Privacy Statement, which shall, unless expressly prohibited by applicable law, be effective from the inception of your use of the Services.
1. Introduction
Sulcus is committed to respecting your privacy and protecting your personal information. In the
course of using its services, Sulcus is likely to collect personal information and you are
likely to communicate such information. The purpose of this policy is to explain the following
to users of the services offered by Sulcus:
How their personal data is collected and processed.
What rights they have to their data.
Who is responsible for processing the personal data collected and processed.
To whom this data is transmitted.
The use of cookies by Sulcus on its websites/ mobile Applications and social medial platforms.
2. Applicable laws
In the course of using its services, Sulcus may collect personal information, and you may disclose such information. The collection, use, communication and retention of your personal information are subject to the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s Anti-Spam Legislation (CASL, Copyright and Intellectual Property, and Consumer Protection Laws.
3. Personal information
Any information that relates to a person and allows that person to be identified is considered personal information. Your personal information may include, but is not limited to, your first and last name, date of birth, residential address, telephone numbers, gender, e-mail address, work information, such as name, title and position, as well as work address, e-mail address and telephone number.
4. Use of Personal Information
We and our service providers may use Personal Information for the following purposes:
Helping to establish and verify the identity of users.
Opening, maintaining, administering and servicing users’ profiles or accounts.
Providing services and support to you.
Improving the Services, including personalizing them and tailoring them to your preferences.
Sending administrative information to you, such as changes to our terms, conditions and
policies.
Sending promotional notices, offers or other targeted marketing, and other information about
Sulcus and its products.
Responding to your questions, inquires, comments and instructions.
Allowing you to participate in sweepstakes, contests and other promotions and to administer
these activities.
Maintaining the security and integrity of our systems.
Complying with legal requirements.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention,
developing new products, improving or modifying our Services, identifying usage trends,
determining the effectiveness of our promotional campaigns and operating and expanding our
business activities.
If you provide any Personal Information relating to other people to us in connection with the
Services, you represent that you have the authority to do so and to permit us to use the
information in accordance with this Privacy Statement.
5. Our commitment
We have established and implemented internal policies and procedures to adequately protect personal information in our possession, regardless of the medium or form in which it is held. We review them on a regular basis.
We make our staff aware of the importance of protecting personal information by requiring them to undergo training on the subject and by issuing occasional directives outlining their role and obligations in this regard.
6. Information gathering objectives
In the course of our activities, we collect your personal and confidential information solely to enable us to provide you with the requested services in an appropriate and personalized manner. In all cases, the disclosure of your personal and confidential information will be subject to obligations to maintain confidentiality and comply with applicable laws.
7. Other Information
"Other Information" is information that does not reveal your specific identity or does not
directly relate to an identifiable individual. Other Information we may collect includes:
Browser and device information.
App usage data.
Information collected through cookies, pixel tags and other technologies.
IP address.
Demographic and other information provided by you that does not reveal your specific identity.
Information that has been anonymized and/or aggregated in a manner that it no longer reveals
your specific identity.
We may use and disclose Other Information for any purpose, except where we are required to do
otherwise under applicable law. If we combine Other Information with Personal Information, we
will treat the combined information as Personal Information.
We and our service providers collect Other Information in a variety of ways, including:
Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that the Services function properly. We also collect a unique device identifier, which we may use for direct marketing purposes.
App usage data: When you download or use our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what parts of the App you use.
Using cookies: Cookies are pieces of information stored on your computer. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively and to personalize your experience. We also gather statistical information about use of the Services to continually improve their functionality, understand how they are used and assist us with resolving questions about them.
If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular site. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
Cookie management You can set your browser or device to refuse cookies or delete them after they have been stored. Please consult the "Help" section of your browser or device for instructions. Please note that deleting or refusing cookies may affect your user experience.
8. Non-personal information
We do not currently respond to browser do-not-track signals.
Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of Services users and email recipients, measure the success of our marketing campaigns and compile statistics about usage and response rates.
Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
IP Address: Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the pages visited. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP Address.
Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We use your device’s physical location to provide you with location-based services and content, such as by returning results that are relevant to your location. We may also use your location with your permission to localize its functions, improve our understanding of our users and for our own- and third- party marketing purposes. You may be permitted to allow or deny such uses and/or the sharing of your device’s location by following the instructions in your device settings.
9. Consent
Subject to the exceptions and requirements of applicable laws, we will not communicate or
disclose your personal information to any third parties without your consent.
By using our services, you consent to the collection, use and disclosure of your personal and
confidential information in accordance with this policy. The form of consent may vary depending
on the context or the service requested.
You may withdraw your consent at any time, subject to certain legal or contractual restrictions.
In certain limited circumstances, we may collect, use or disclose personal information without
your knowledge or consent. Such circumstances may arise, for example, when, for legal, medical
or security reasons, it is impossible or unlikely to obtain your consent, or when the
information is required to investigate a possible breach of contract, to prevent or detect
fraud, or to enforce the law.
Before disclosing personal information about another person to us, you must obtain that person’s
consent to the disclosure and processing of that personal information under the terms of this
policy.
9.1 Personal information concerning a minor
Personal information concerning minors under 14 years of age will not be collected from them without the consent of the parent or guardian.
9.2 Disclosure
We may disclose your personal information to any of our staff, professional advisers, suppliers, or sub-contractors or subsidiaries to the extent reasonably necessary to provide the services requested and for the purposes set out in this policy.
As a general rule, we do not disclose your personal information. Occasionally, we may share your personal information with certain suppliers or agents in order to provide the services you have requested. In all cases, we comply with the restrictions and requirements set out in the Act when we disclose your personal information and, in certain circumstances, this is subject to a written agreement and a security assessment demonstrating that your personal information benefits from adequate protection similar to that in place within Sulcus.
Your personal information will not be disclosed to third parties other than in accordance with this Privacy Policy, except as required or permitted by law, or as ordered by a court of competent jurisdiction.
We do not sell your personal information to third parties.
9.3 Impact assessment
A Privacy Impact Assessment (PIA) on the use of personal information by our services and/or systems is conducted before any personal information is collected by Sulcus.
9.4 International data transfers
The information we collect may be stored, processed and transferred in all countries in which
Sulcus and its subcontractors offer their services, in order to enable us to use the information
in accordance with this policy.
The information we collect may be transferred to or processed in the following countries: the
United States of America, Canada, India, United Kingdom.
Personal information that you publish on our website and/or Mobile Application or submit for
publication may be available worldwide via the Internet. We cannot prevent the use, good or bad,
of this information by third parties.
You expressly agree to the transfer of personal information as described in this section.
10. Retention of information
When your personal information is no longer required, it is destroyed in accordance with the Act
and our records retention policy. In certain circumstances, we may anonymize the personal
information we retain.
Your personal and confidential information is retained, directly or through subcontractors, only
as long as necessary for the provision of the requested services and to meet applicable legal
and regulatory requirements. We require our subcontractors to subscribe to confidentiality
commitments and to apply policies equivalent to this one. In all cases, access to your personal
and confidential information is restricted to those persons for whom access is necessary for the
performance of their duties.
11. Security
Sulcus takes reasonable precautions designed to protect your Personal Information. Please be aware, however, that no data transmission or storage system can be guaranteed to be completely protected against unauthorized interception. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Queries" section below.
12. Liability
We are responsible for personal information in our possession or custody, including information
we entrust to third parties for the purpose of providing you with the requested service. We
require these third parties to maintain this information under strict confidentiality and
security standards.
We adhere to the principles set out in the Act. We have policies and guidelines in place to
ensure that your privacy is protected. The Privacy Officer oversees this privacy policy and the
company’s various frameworks.
Our staff is informed and properly trained on privacy policies and practices.
13. Information security measures
We have implemented a number of information security measures with respect to the personal information and confidential data we hold in order to protect such information against loss or theft and to prevent unauthorized access, transmission, use or modification of such personal information, including the following subsections:
13.1 Privacy Impact Assessment
Sulcus performs a Privacy Impact Assessment (PIA) on any project involving the acquisition, development or redesign of an information system or the electronic delivery of services that involves the collection, use, disclosure, retention or destruction of personal information. This assessment documents the serious and legitimate interest in the use of personal information.
13.2 Secure computing environments
Infrastructure and equipment are hosted in a secure environment in a data center located in
Saskatchewan, Canada. In cases where it is impossible to host a solution or service in
Saskatchewan, we ensure that security measures equivalent or superior to those required by this
Policy are put in place.
Access to Sulcus web services is via a secure SSL (HTTPS) transmission channel.
13.3 Access management
Only those members of our staff whose duties require it have access to personal or confidential information. Data access is logged and monitored.
13.4 Training and awareness-raising
Our staff and partners are trained and made aware of the importance of protecting your personal information.
13.5 Commitment to confidentiality
Our staff members sign a confidentiality agreement.
Security audits are carried out by firms specializing in information security.
13.6 Destruction
Sulcus ensures the physical and technological security of the personal information it holds in order to prevent accidental destruction, loss, disclosure or inappropriate destruction.
We retain your personal information only as long as necessary for the purposes for which it was collected. We must destroy or anonymize such information in accordance with the Act and our retention schedule. When we destroy or anonymize your personal information, we take the necessary steps to ensure its confidentiality and that no unauthorized person has access to it during the destruction or anonymization process.
13.7 Managing incidents involving personal information.
If Sulcus has reason to believe that a confidentiality incident involving personal information has occurred and that there is a risk of serious harm caused by the incident, Sulcus will, with due diligence, inform the Office of the Privacy Commissioner of Canada and any person whose personal information is affected by the incident. Sulcus may also notify any person or organization that may be able to mitigate this risk, by communicating only the personal information required for this purpose without the consent of the person concerned. In all cases, a log will document the incident for reference purposes.
14. User rights: Request for access, withdrawal or correction
Subject to any regulatory or contractual restrictions, you may consult, correct or destroy the personal information we hold about you.
We will send you such information within a maximum of 30 days from the date of receipt of the written request and in a structured, commonly used technological format. A fee may be charged for processing your request.
Under certain circumstances, we may refuse to provide you with the information you have requested. Exceptions to your right of access include the fact that information cannot be disclosed for legal or security reasons. These limitations are described in the Personal Information Protection and Electronic Documents Act.
You may verify the accuracy and completeness of your personal information and, if necessary, request that it be amended. Any request for amendment will be processed in accordance with the Act.
14.2 Changes to the mobile Application and Disclaimer
We reserve the right to modify or discontinue the App at any time without notice for users in Canada. We may also update this Disclaimer from time to time. Canadian users are encouraged to review the Disclaimer periodically for any changes.
14.3 Data portability
Users have the right to request the portability of their personal data held by Sulcus to another site.
14.4 Limiting and objecting to data processing
The user has the right to request that Sulcus restrict or object to the processing of their data, and Sulcus may not refuse this request unless it can demonstrate the existence of legitimate and compelling reasons, which may override the interests and rights and freedoms of the user.
14.5 Decision based exclusively on an automated process
The user has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning them, or significantly affects them in a similar way.
15. Inquiries, complaints and questions
We are committed to responding to your questions and concerns regarding the protection of your personal information. If you are not satisfied with the response, you may contact Sulcus.
16. Revision and approval
This Policy comes into effect immediately and may be revised at any time by the Privacy Officer.
Sulcus reserves the right to modify this policy at any time. Any changes will be posted on Sulcus’s various web and mobile applications platforms. Your use of the Services following the posting of changes to the Policy constitutes acceptance of those changes.
17. Queries
SULCUS is committed to working with consumers to obtain a fair and rapid resolution of any queries, complaints or disputes about privacy. Please send us your questions or comments regarding our privacy practices by emailing us at support@sulcuslearning.com or sending us a letter addressed to: 700-2010 11th Ave, Regina SK S4P 0J3
Our Disclaimer was updated on November 30th, 2023.
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Disclaimer: