privacy policy

Last Updated: August 3rd, 2018

Introduction

At Cerbo, Inc. (“Cerbo”, “We” or “Us” and terms of similar meaning), we are committed to your privacy. This means we do not transfer, distribute, disclose, rent or sell any of your personal information to third parties except as provided for in this policy (the “Privacy Policy”) or as specifically consented by you.

Cerbo has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws. By accepting this Privacy Policy in registration or by visiting and using our Cerbo Platform (the “Site”) and/or utilizing the services through the Site (the “Services”), you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms of Service.

Scope

This Privacy Policy applies to all personal information (“Personal Information”) collected, used or disclosed by Cerbo from our customers, instructors and users who may use the Services (collectively “Users”).

Accountability

Cerbo is responsible for the Personal Information under our possession and control. We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.

Information we collect

a. Personal Information

Personal information is any information recorded in any form that identifies or can identify an individual and includes any information provided to us by you or your Users in using our Site and Services. Personal information includes, but is not limited to, the following:

  • registration and verification information and user profile information that you provide to us in creating your account to use our Services (e.g. name, address, email address, government identification, and telephone number);
  • information about the courses you register for and your interests;
  • financial and billing information (such as credit card number and expiration date);
  • demographic information (such as age, education, occupation) and information about individual preferences;
  • learner data, including notes, results and other course content (“Learner Information”);
  • survey and feedback information regarding instructors;
  • User registration information, including profile pictures;
  • User registration information, including profile pictures;
  • information collected from third party services that you connect to our Service;
  • any communications and personal information that you provide through our messaging system, or comment and feedback forms; and
  • any information that Cerbo collects from you is intended to improve and personalize your service experience.

b. Non-Personally Identifiable Information

Personal information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any User. This may include grades and participation rates aggregated among many Users. Such information by itself or together cannot be tracked to a specific individual’s personally identifiable information.

How do we use Personal Information?

Cerbo collects Personal Information for the following purposes:

  • to provide Services to you and your Users;
  • to establish and maintain responsible commercial relations and to communicate with you in order to provide service. This includes, but is not limited to, communications relating to billing, payments, advertising, promotion and account verification;
  • to respond to any correspondence you may direct to us;
  • to understand, research, and improve our Services, including understanding survey data and User feedback;
  • customer and User needs and preferences;
  • to direct advertisements to you about our company and our products and services that may be of interest to you;
  • to enforce our Terms of Service and legal agreements;
  • to provide you with system or administrative messages;
  • to meet legal and regulatory requirements; and
  • for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied.

How do we use Non-Personally Identifiable Information?

In an ongoing effort to better understand and serve the users of our Services and improve our Service and user functionality, we conduct research on our customer and User demographics, learner interests and course information, and behavior based on Personal Information and other information that we have collected. This research may be used by Cerbo to analyze and improve our services to our customers, suggests courses and instructors that may of interest to our customers and to direct advertising to our customers. This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered and treated as Non-Personally Identifiable Information under this Privacy Policy.

Consent

We respect your privacy and, unless otherwise required by law, we will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means. In certain circumstances, your consent may be implied by your actions. For example, providing us Personal Information to register for our Services is implied consent to use such information to provide you the associated services.

Where appropriate, Cerbo will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Cerbo wants to use information for a purpose other than those identified above). In obtaining consent, Cerbo will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by Cerbo may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Cerbo shall take into account the sensitivity of the Personal Information and the reasonable expectations of our customers and Users. Cerbo will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, however, withdrawing consent may result in our inability to provide you with certain Services. In order to withdraw consent, you must provide notice to Cerbo in writing.

Limiting Use, Disclosure and Retention

Unless required by law, or in connection with a business transaction, Cerbo shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining your consent, where such consent may not reasonably be implied.

As noted above, Cerbo does not disclose your Personal Information to third parties. Notwithstanding, your Personal Information may be transferred to third party suppliers, contractors and agents (“Affiliates”) who are contracted by Cerbo to assist it in providing and developing products and services, for example customer service and user support, and payment processing. Such Affiliates will only use your Personal Information for the purposes identified in this Privacy Policy. Such Affiliates may be located outside of Canada and the United States, and your Personal Information may be collected, used, disclosed, stored and processed in such jurisdictions for the purposes described in this Privacy Policy. Cerbo takes reasonable contractual or other measures to protect your Personal Information while processed or handled by such Affiliates. If your Personal Information is located outside Canada or the United States it will be subject to legal requirements in those foreign countries applicable to our service providers, for example, lawful requirements to disclose Personal Information to government authorities in those countries.

In the event your Personal Information is disclosed to a third party pursuant to a business transaction (including a potential sale or financing), Cerbo will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only Cerbo’s and our Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about our Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.

Cerbo will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Cerbo.

Using the Site & Cookies

In order to improve the Site, we may use small files commonly known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Site and is stored on your device’s browser or hard drive. Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may generate reports based on the use of these technologies an aggregated basis

The cookies we use on the Site won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties. We use cookies to remember users’ settings, store login addresses, authenticate users, run website experiments, and store analytics data, such as browser, device type and operating system.

Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

Cookies from third parties

We use Google Analytics, a web analytics service provided by Google Inc. ("Google") on the Site. Google Analytics uses "cookies", which are text files placed on your computer, to help the Sites analyse how users use the Site. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Sites. By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

We may use additional third party and such parties will have their own privacy policies describing how they use information that they collect.

How can I Access my Personal Information?

Upon request, Cerbo will provide information to a User regarding the existence, use and disclosure of his or her Personal Information. Cerbo will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. A User may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, Cerbo may not be able to provide access to all the Personal Information it holds about a User. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Cerbo will provide the reasons for denying access upon request.

Safeguards

We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your personal information is stored and archived are secure and in a controlled environment with limited access. We educate our employees with respect to their obligations to protect your personal information.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our website if you consider that information to be sensitive.

Challenging Compliance

An individual will be able to address a challenge concerning compliance with this Privacy Policy to Cerbo's Privacy Officer.

Cerbo will maintain procedures for addressing and responding to all inquiries or complaints from Users about Cerbo's handling of Personal Information. Cerbo shall investigate all complaints. All inquiries or complaints involving Cerbo's handling of Personal Information or compliance with this policy or with PIPEDA shall be directed to Cerbo's Privacy Officer.

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Cerbo finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact our Privacy Office as follows:

E-mail: contact@cerbo.me

Mail:

C/O Farris Vaughan Wills & Murphy Llp
1800-1631 Dickson Avenue (Landmark 6)
Kelowna Bc V1y 0b5
Canada

Children and Minors

Our Site and the Services offered on our Site are not directed to children under the age of 13 years. We will not knowingly collect Personal Information about a child under the age of 13.

We only collect Personal Information through the Services and/or the Cerbo Platform from a minor defined as someone that is under the age of 16 or the legal age in your jurisdiction) where that user’s parent or guardian has provided consent to Cerbo to collect, use and disclose such Personal Information in accordance with this Privacy Policy.

General

Cerbo reserves the right to modify and amend this privacy policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our Site and will be effective as of the date of posting.