Last Updated February 8 2021
Table of Contents
- INFORMATION WE COLLECT ABOUT YOU
- HOW WE COLLECT INFORMATION ABOUT YOU
- INFORMATION YOU PROVIDE US
- INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES
- HOW WE USE YOUR INFORMATION
- DISCLOSURE OF YOUR INFORMATION
- TRANSFERRING YOUR PERSONAL INFORMATION
- CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
- DATA SECURITY
- DATA RETENTION
- CHILDREN UNDER THE AGE OF 16
- ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
- WITHDRAWING YOUR CONSENT
- CONTACT INFORMATION AND CHALLENGING COMPLIANCE
- RESIDENTS OF THE EUROPEAN ECONOMIC AREA
- RESIDENTS OF CALIFORNIA
- GOOGLE USER DATA
- GOVERNING LAW
- FOR MORE INFORMATION OR ASSISTANCE
Enrollment Resources Inc. is a Canadian Company focused on connecting students with schools. We help schools with website and paid search management. We help students decide if a school is right for them. In doing so, we help our clients collect data from students. Read more below to find out how exactly we do this.
Enrollment Resources Inc. and our affiliates and subsidiaries (“Company” or “We”) respect your privacy and are committed to protecting it by complying with this policy. We understand that as a data subject, your information is important to you.
This policy describes:
• How we collect, use, disclose, and protect the personal information of our customers and website users (“you”).
• The types of information we may collect from you or that you may provide when you visit this website (our “Website”), or affiliate websites. This may include, but is not limited to: https://enrollmentresources.com/, and virtualadviser.com.
• 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 as set out in this policy.
Privacy laws in Canada, the United States, and the European Union may generally define “personal information” as any information about an identifiable individual, consumer, or household, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Note, data protection laws in several jurisdictions draw comparison between the “controllers” and “processors” of personal information. In general, Enrollment Resources performs the role of a processor on behalf of our clients who are the controllers.
This policy applies to information we collect, use, or disclose about you:
• On this Website.
• In email, text, phone and other electronic messages 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.
• Through any of our affiliate companies.
• including on any other Company or third-party website (including our affiliates and subsidiaries).
This policy DOES NOT apply to information that:
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. 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.
INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including:
• Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, and any other identifier we may use to contact you (”personal information”). We also collect any other information you choose to send us. Please do not provide us with your billing and account information, social insurance number, or health card number. Furthermore, do not provide us with any criminal, or offence history.
• We provide an opportunity for any user to unsubscribe from our emails or opt-out of contact for marketing or data purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or by e-mailing to [email protected].
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, search terms and search engines, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
• Analytics, such as Google Analytics
• When you visit our websites, we may automatically collect certain information, such as:
• Ad group, keyword, and other data about the ad you clicked on to navigate to our website
• This is standard practice for websites, and is not used for any purpose other than to evaluate how we can design the site to best serve your needs.
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 registering online, or use of any of our products or services.
• User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties.
• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, domain, country and information collected through cookies, web beacons, and other tracking technologies.
• Third parties or publicly available sources, for example, our business partners.
• FullContact Person API. We use your email address to look up additional publicly available data including public profile picture, and social media profiles.
• The use of unique phone numbers to record calls.
INFORMATION YOU PROVIDE 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, 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. In particular, we collect the information your provide when you fill in our “I Want Answers” section, or the “Is this School Right for you? Find Out!” features.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Details of transactions you carry out through our Website and of the fulfillment of your orders.
• Your search queries on the Website.
• Information you post to any “third party affiliates”
INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES
• 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.
We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
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 way 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:
• 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 below for “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).
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 and an opt-out tool created by the Network Advertising Initiative. 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 below for “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 provide you with information, products, or services that you request from us. For example, the Career Training Readiness Quiz asks several questions to evaluate whether you would be a good fit to attend the educational institution.
• To email you regarding your progress on our website. You may receive emails inviting you to finish your evaluation if you leave before completing. You may receive confirmation emails if you choose to book an appointment with an educational institution. You may receive a report via email that contains the personal information provided, as well as the evaluation provided by our website.
• To share your information with the education institution represented when you register, may contact you to recommend their products or services.
• 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.
• To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• 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 [email protected]. For more information, see below for “Choices About How We Use and Disclose Your Information”.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION
We do not sell any of your information to third parties. However, we may disclose aggregated information about our users, and information that does not identify any individual.
• To our subsidiaries and affiliates.
• To the controller of the website in which you input data.
• 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 Enrollment Resources Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Enrollment Resources about our customers and users is among the assets transferred.
• To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers’ advertisement to that target audience.
• To third parties to market their products or services to you if you have consented to these disclosures. We may 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 below for “Choices About How We Use and Disclose Your Information”.
• 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.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Enrollment Resources Inc., 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 at [email protected] to obtain further information about Company policies regarding service providers outside of Canada.
• By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
• The information supplied to us may be collected, used, disclosed, stored, or processed in Canada, the United States of America, the United Kingdom, or the European Union.
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:
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request to [email protected].
• 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 and an opt-out tool created by the Network Advertising Initiative. 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.
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. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted using SSL technology. Our data is stored in Canadian and the United States.
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.
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.
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. Generally, we retain your data for 5 years. 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.
CHILDREN UNDER THE AGE OF 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].
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 [email protected] 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.
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at [email protected].
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 at [email protected]. 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 with your decision. It may take up to 3 business days to fulfill your request.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
#216-611 Brookside Road
Victoria, British Columbia
Canada V9C 0C3
or our phone number (00) 1-250-391-9494
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 our Privacy Officer using the contact information listed above.
RESIDENTS OF THE EUROPEAN ECONOMIC AREA
In addition to the common rights granted to all users of the Site who provide us with Personal Information, the GDPR provides the following additional rights to residents of the European Economic Area:
• Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Information, as permitted by law.
• Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances.
• Right to data portability (Art. 20 GDPR): You have the right to receive the Personal Information that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
• Right to object (Art. 21 GDPR): You have the right to object to our processing of your Personal Information, as permitted by law.
• Right to lodge a complaint before the Data Protection Authority (Art.77 GDPR): We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Information relating to you infringes applicable data protection laws.
RESIDENTS OF CALIFORNIA
We do not sell Personal Information and have not done so in the past 12 months.
The CCPA provides Californian resident consumers and users with specific rights regarding their personal information.
Information We Collect
We have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, physical characteristics or description, address, telephone number, education, employment, employment history, Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you:
• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Enrollment Resources delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
• Complete the transaction for which your Personal Information was collected, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability and Deletion Rights
To exercise the access, data portability and deletion rights described above, please submit a valid consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify that you are the person we collected Personal Information from or an authorized representative on your behalf.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
GOOGLE USER DATA
Our software may give you the option to login with your Google Account to enable additional functionality. Currently, we use Google User Data for the following:
- Displaying relevant Google Analytics data from your website to compare with our visitor data, and calculate conversion rates in a convenient dashboard.
FOR MORE INFORMATION OR ASSISTANCE
#216-611 Brookside Road
Victoria, British Columbia
Attention: Chief Privacy Officer.