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  1. INTRODUCTION

IPN Brainpower Consulting Inc. (referred to as “we”, “us” or “our” in this Privacy & Cookie Policy) is a Canadian-based business that is committed to keeping your personal data safe. Personal data means any information capable of identifying an individual. It does not include anonymised data. This Privacy & Cookie Policy has been prepared based on provisions of global legislations, including the Canadian Privacy Act 1983, The Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and the E.U./U.K. General Data Protection Regulation (GDPR).

This Privacy & Cookie Policy provides you with details of how we collect and process your personal data through your use of our website, including but not limited to its content, materials, resources, programs, products, services, opt-in gifts, ebooks, videos, webinars, blog posts, e-newsletters, podcasts, consultations, emails, relevant social media pages including any associated groups and/or other communication (collectively referred to as “website”), whether as a guest or registered user:

This policy (together with our Terms of Use & Disclaimer, and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following terms carefully to understand our views and practices regarding your personal data.

BY USING OUR WEBSITE, YOU ACCEPT THIS POLICY AND AGREE TO ABIDE BY IT. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE OUR WEBSITE.

Our website is not directed to individuals under 18. We do not knowingly collect personal data from young people under 18. If we become aware that a person under 18 has provided us with personal data, we will take steps to delete such information. If you become aware that a minor has provided us with personal data, please contact us.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at policies@brainpower360.ca

  1. DATA COLLECTION & PROCESSING

We collect data about you by you providing the data directly to us (for example by filling in forms on our website, sharing resources with us such as uploading content or commenting publicly, or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

We may receive data from third parties such as analytics providers (such as Google based in the U.S.), advertising networks (such as Facebook based in the U.S., Google based in the U.S., Instagram based in the U.S. and LinkedIn based in the U.S.), such as search information providers (such as Google based in the U.S.) and/or other providers of technical, scheduling, payment and delivery services (Automattic (here: Woocommerce) based in the U.S., Rocketgenius (here: Gravity Forms) based in the U.S., Mighty Software (here: Mighty Networks) based in the U.S., SendOwl based in the U.K., Zoom based in the U.S., Demio based in the U.S., Acuity Scheduling based in the U.S., Stripe based in the U.S., PayPal based in the U.S., Apple (here: ApplePay) based in the U.S., Aweber based in the U.S.).

We may process the following categories of personal data about you:

  • Communication Dataincludes any communication/enquiries that you send to us whether that be through forms on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record-keeping and the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
  • Prospect Dataincludes data relating to any sign-up for our free resources (through our website or otherwise) such as your name, email address, phone number and contact details. Based on the consent you have given, we process this data for the purposes of us sending you the free resource(s) and for record-keeping. Our lawful ground for this processing is our legitimate interests which in this case are to fulfil your requests and to keep records.
  • Customer Dataincludes data relating to any purchases of products/services such as your title, name, billing address, delivery address, email address, phone number, contact details, purchase details and your payment details. We process this data to supply the products/services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • Business & Financial Dataincludes data relating to any purchases of products/services such as your title, name, billing address, delivery address, email address, phone number, contact details, purchase details and your payment details. We process this data to supply the products/services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
  • User Dataincludes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
  • Technical Dataincludes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
  • Marketing Dataincludes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is our legitimate interests which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent. You can ask us to stop sending you our marketing messages at any time by following the opt-out links on our marketing message sent to you or by emailing us at policies@brainpower360.ca at any time.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, registrations etc.

Where we are required to collect personal data by law, or under the terms of the contract between you and us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver products/services to you). If you do not provide us with the requested data, we may have to cancel the products/services you have ordered, but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or automated profiling that produces legal effects or similarly significantly affects you as an individual.

We do not collect any information about criminal conviction and offences.

SPECIAL CATEGORY DATA

Special category data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any special category data about you.

  1. DISCLOSURE OF PERSONAL DATA

We may have to share your personal data with the parties set out below:

  • Organisations that provide services to us and as part of those services they need to process your personal data
  • Professional advisers including lawyers, accountants, bankers, auditors and insurers.
  • Government bodies that require us to report processing activities.
  • Agencies such as fraud prevention and credit rating agencies.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

  1. INTERNATIONAL TRANSFERS

Depending on your location, data transfers may involve transferring your data to a country other than your own. Where we transfer your personal data to third parties outside of Canada (where we are based)/E.E.A./U.K. (as the case may be), we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.

As such:

  • We may transfer your personal data to countries that the European Commission or the U.K. (as the case may be) have approved as providing an adequate level of protection for personal data by: or
  • If we use U.S.-based providers that are part of E.U.-U.S. Privacy Shield or the U.K.-U.S. Privacy Shield (as the case may be), we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission or the U.K. government (as the case may be) which give personal data the same protection it has in Europe or the U.K. (as the case may be).

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

  1. DATA SECURITY

We use reasonable technical precautions and have implemented security measures and business processes to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those third-parties who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

  1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, the Canadian law requires us to keep basic information about our customers (including contact, identity, financial and transaction data) for five (7) years or more depending on the lodgement date of our tax return.

In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. ACCESS RIGHTS

Under data protection law, you have certain rights in relation to your personal data.

If the GDPR applies to the processing of your personal data, such data protection laws include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please email us at the email address set out at the top of this Privacy & Cookie Policy. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you have already contacted us and feel that your complaint cannot be resolved between the two of us, you have the right to complain to a relevant supervisory authority for data protection issues (such as the Office of the Privacy Commissioner of Canada’s Office (OPC; https://www.priv.gc.ca/) or any other equivalent).

  1. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice (or privacy policy) of every website you visit.

  1. COOKIES

A “Cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system. We use cookies to track your use of our website. This enables us to understand how you use the website and track any patterns with regards to how you are using our website. This helps us develop and improve our website as well as products/services in response to what you might need or want.

If you are from the E.U./U.K., we are required to obtain your consent for all non-essential cookies used on our website. Even after you have consented to the use of cookies via our cookie consent mechanism, you can block cookies (including essential cookies) at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

No matter where you are from, please note that if you use your browser settings to block essential cookies, you may not be able to access all or parts of our website.

Cookies are either:

  • Session Cookies:These are only stored on your computer during your web session and are automatically deleted when you close your browser; they usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any personal data from your computer; or
  • Persistent Cookies: A persistent cookie is stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.

Cookies can also be categorised as follows:

  • Strictly Necessary Cookies:These cookies are essential to enable you to use the website effectively, such as when buying a product/service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance Cookies:These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the website are most popular.
  • Functionality Cookies:These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested, such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
  • Targeting Cookies:These cookies record your visits to websites in general, the pages you visited and the links you have followed. This information is used to make websites and the advertising displayed on it more relevant to your interests.
  • First- and Third-Party Cookies Cookies: First-party cookies are cookies set by our website. Third-party cookies on our website that are set by a website other than our website, such as where we have adverts on our website or use Facebook/Instagram/LinkedIn pixels so that we can show you relevant content from us when you are on those third-party platforms.

YOU CAN FIND MORE INFORMATION ABOUT THE INDIVIDUAL COOKIES WE USE AND THEIR SOURCE DOMAIN BY CLICKING THE FOLLOWING LINK: >> VIEW COOKIE TABLE <<

You can alter your cookie preferences at any time by clearing cookies in your browser. The next time you visit our site, you will be asked again for your cookie preferences.

You can also control your cookie settings through your web browser.

You can opt out of being tracked by Google Analytics across all websites by going to https://tools.google.com/dlpage/gaoptout.

If you have any questions about the cookies that we use, feel free to email us at policies@brainpowe360.ca

ADDITIONAL RESOURCES

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/ and/or read this informative Wikipedia article on HTTP Cookies.

In addition, check out the Your Online Choices resource; it describes how you can select your preferences for most of the advertising tools out there.

You can find information about how to manage cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.

If you want even more guidance, follow the instructions provided on the subsequently linked initiatives by the EDAA (E.U.), the Network Advertising Initiative (U.S.) and the Digital Advertising Alliance (U.S.), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow you to select your tracking preferences for most of the advertising tools.

  1. VARIATIONS

We may change this Privacy & Cookie Policy from time to time. If we do so, we will post the latest version on this page and, if the changes are significant, we will send you an email notification, if possible. Also, we will keep prior versions of this Privacy & Cookie Policy in an archive for your review. We encourage you to review our Privacy & Cookie Policy whenever you use the website to stay informed about our practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy & Cookie Policy, you will need to stop using the website.

  1. SUPPORT

If you want to contact us or have any questions regarding this Privacy & Cookie Policy, please email us at the email address set out at the top of this page (under contact details).