PRIVACY POLICY
THIS POLICY made effective the 15th day of August, 2019.
Article I
INTRODUCTION
1.1 THE PILATES BARRE GP LTD. and our affiliates and subsidiaries (the “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.
1.2 We collect, use and disclose information in accordance with the Personal Information Protection Act (Alberta).
1.3 This policy describes how we collect, use, disclose and protect the personal information of our customers, app, social media and website users (“you”). It describes the types of information we may collect from you or that you may provide when you interact with us directly, visit our website, www.pilatesbarregp.com (the “Website”), our Facebook, Instagram or Twitter page (the “Social Media”), or use the My Pilates Barre GP app (the “App”) (collectively, the “Technology”), and outlines our practices for collecting, using, maintaining, protecting and disclosing that information.
1.4 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.
1.5 The Technology 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.
1.6 Please read this policy carefully to understand our policies and practices for collecting, process and storing your information. If you do not agree with our policies and practices, your choice is to not use the Technology. By accessing or using the Technology, 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 the Technology after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use and disclose your personal information.
Article II
COLLECTING INFORMATION
2.1 We collect and use several types of information from and about you including:
(a) 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, user name or other similar identifier, billing and account information and any other identifier we may use to contact you online or offline (“Personal Information”)
(b) Financial information which may include your credit card information and other information to facilitate payment for services provided.
(c) Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified 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 that access a specific App function.
(d) 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 the Technology and usage details.
(e) Non-personal details about your interactions with the Technology including the full Uniform Resource Locators (URLs), clickstream to, through and from the Technology (including date and time), products you viewed or searched for, 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. This helps us to improve the Technology and to deliver better and more personalized services by enabling us to estimate our audience size and usage patterns, speed up your searches, recognize when you return to the Technology and store information about your preference which allows us to customize the Technology according to your individual interests.
(f) Device Information. We collect information from and about the computers, phones and other web-connected devices you use that integrate with our products, and we may combine this information across different devises you use. Information we obtain from these devices include:
(i) Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types and plugins.
(ii) Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded or mouse movements
(iii) Device signals: bluetooth signals, and information about nearby Wi-Fi access points, beacons and cell towers.
(iv) Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
(v) Network and Connections: information such as the name of your mobile operator or internet service provider (ISP), language, time zone, mobile phone number, IP address, connection speed.
(vi) Cookie data: data from cookies stored on your device, including cookie IDs and settings. 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 the 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 the Website.
(vii) Flash cookie data: certain features of the Technology may use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from, and on the Technology. Flash cookies are not managed by the same browser settings that are used for browser cookies.
(viii) Web beacon data: pages of 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).
2.2 We use different methods to collect your information, including through:
(a) Direct interactions with you when you provide it to us, for example, by filling in forms, completing surveys or corresponding with us in person, by phone, email or otherwise.
(b) User contributions. You may also provide information for us to publish or display on public App, Social Media or Website areas or to transmit to other App, Social Media or Website users or third parties.
(c) Automated technologies or interactions as you navigate through the Technology. Information collected automatically may include usage details, traffic data, location data, communication data, IP address, and information collected through cookies and other tracking technologies.
(d) Third parties or publicly available sources, for example, our business partners.
Article III
HOW WE USE YOUR INFORMATION
3.1 We use information that we collect about you or that you provide to us, including any personal information:
(a) To present the Technology and its contents to you.
(b) To provide you with information, products or service that you request from us.
(c) To improve and personalize the Technology, products or services, marketing or customer relationships and experiences.
(d) To fulfil 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.
(e) To provide you with notices about your account and subscription including expiration and renewal notices.
(f) 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.
(g) To notify you about changes to the Technology or any products or services we offer or provide through it
(h) To allow you to participate in interactive features, social media, or similar features on the Technology.
(i) To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
(j) In any other way we may describe when you provide the information.
(k) For any other purpose with your consent.
Article IV
DISCLOSURE OF YOUR INFORMATION
4.1 We may disclose aggregated information about our users and information that does not identify any individual without restriction.
4.2 We may disclose personal information that we collect, or you provide as described in this privacy policy:
(a) To our subsidiaries and affiliates
(b) 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 or some of all of THE PILATES BARRE GP LTD.’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, un which personal information held by THE PILATES BARRE GP LTD. about our customers and users is among the assets transferred.
(c) 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, Social Media and App 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 as set out in this policy.
(d) To fulfil the purpose for which you provide it or that were described when it was collected, or any other purpose for which you provide it;
(e) With your consent.
4.3 We may also disclose your personal information:
(a) To comply with any court order, law or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
(b) To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
(c) If we believe that disclosure is necessary or appropriate to protect the rights, property or safety of THE PILATES BARRE GP LTD., our customers, or others.
Article V
TRANSFERRING YOUR PERSONAL INFORMATION
5.1 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 analytic and search engine providers that assist us with the improvement and optimization of the Technology) 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.
5.2 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.
5.3 By submitting your personal information or engaging with the Technology, you consent to this transfer, storage or processing.
Article VI
DATA SECURITY
6.1 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, including, but not limited to, the following:
(a) Storing physical records containing your personal information in a secure place;
(b) Storing electronic records on secured hardware, using antivirus software and passwords on all computers and taking care to protect screen monitors from public viewing;
(c) Transferring physical records outside our office in sealed envelopes by secure methods;
(d) Conducting telephone discussions with sensitivity to ensure that your personal information is not inadvertently disclosed; and
(e) Training staff to handle information only through the protected measures outlined in our privacy procedures.
6.2 We do not share your personal information outside our office for any marketing, promotional, publicity, educational or research purposes without your consent.
6.3 The safety and security of your information also depends on you. Where we have given (or where you have chosen) a password for access to certain parts of the Technology, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
6.4 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 the Technology. 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 Technology.
Article VII
DATA RETENTION
7.1 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.
Article VIII
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
8.1 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.
8.2 You can review and change your personal information by logging into the Website or the App and visiting your account profile page.
8.3 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.
8.4 Request for access to a record or for correction of personal information can be directed to Tori Smith at:
Address: #101, 10132 100 Ave
Grande Prairie, Alberta T8V 0V5
Email: info@pilatesbarregp.com
Phone: 780-832-5620
Article IX
WITHDRAWING YOUR CONSENT
9.1 Where you have provided your consent to the collection, use and disclosure of your personal information, you may have the legal right to withdraw your consent under certain circumstances. 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 with your decision. To withdraw your consent, please contact Tori Smith at:
Address: #101, 10132 100 Ave
Grande Prairie, Alberta T8V 0V5
Email: info@pilatesbarregp.com
Phone: 780-832-5620
Article X
CHANGES TO OUR PRIVACY POLICY
10.1 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 notify you by email to the email address specified in your account or through a notice on the Website, Social Media or App home page. 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.
Article XI REQUESTS, QUESTIONS AND CONCERNS
11.1 If you have a request, question or concern about any collection, use or disclosure of information by the Company, please contact Tori Smith at:
Address: #101, 10132 100 Ave
Grande Prairie, Alberta T8V 0V5
Email: info@pilatesbarregp.com
Phone: 780-832-5620
11.2 If you are not satisfied with the response you receive from the Company, you may contact the Office of the Information and Privacy Commissioner of Alberta (Edmonton) at:
Address: #410, 9925-109 Street
Edmonton, Alberta T5K 2J8
Phone: 780-422-6860
Toll Free: 1-888-878-4044
Fax: 780-422-5682