Skooli Inc. (in this policy, “Skooli”), recognizes the importance of confidentiality and the protection of personal information. This privacy policy explains how we use and protect the personal information we hold, whether it relates to our students, parents, tutors, potential tutors, its staff, consultants and third party service providers in connection with our business and has been developed to comply with Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA").
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of our websites or sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.
Personal information means information about an identifiable individual or information that permits an individual to be identified. It does not include business contact information, such as name, title, business address and business telephone number when used for business communications.
Skooli takes responsibility for maintaining and protecting the personal information under our control. We have appointed a Chief Privacy Officer who can be contacted directly by the public who is responsible for our day to day compliance. We review this policy and our personal data protection practices regularly to ensure that we are in compliance with applicable legislation and current best practices. We do not knowingly collect any personal information from children under the age of 13 and the services offered by Skooli are not intended for use by children.
We only collect personal information as required to meet the purposes that we have identified. We do not indiscriminately collect or retain personal information.
Skooli typically collects personal information that is voluntarily provided by the individual in question. At times, however, personal information is obtained from other sources, such as government bodies or third parties such as employers, references and service providers, as permitted by law. Where the purpose for the collection of personal information is unclear, you can ask the Skooli representative with whom you are dealing to provide an explanation of the purpose for the data collection.
Our reason for collecting personal information about tutors, students, parents, staff and consultants is to establish and maintain our contractual or other business relationship with that individual.
The purpose for collecting personal information about tutors and students is primarily to facilitate the provision of educational tutoring services online, including to allow students to quickly and easily assess the professional and educational background of tutors, as well as allowing us to communicate effectively with our tutors, students and parents and to maintain mailing lists. We may also use your personal information to:
As appropriate, Skooli will ask for specific consent to collect, use and disclose personal information, including for the purposes of completing or arranging for the completion of background checks and other searches. Such a request, and your consent to such request may be given in writing or orally. In some cases, consent can be implied through an individual relationship or conduct with us, depending on the sensitivity of the information.
PIPEDA permits Skooli to disclose personal information to third parties without the affected party’s knowledge or consent to certain parties. Accordingly, we may share personal information about you as follows:
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
Personal information supplied to us is confidential and we do not disclose the information to any third party except with actual or implied consent, or as permitted or required by law. We do not exchange or sell personal information.
Skooli may use third party service providers from time to time to carry out certain functions for us such as printing, storage, shredding or document scanning. Where we use such outside service providers, we require those third parties to protect personal information in the same manner in which we protect it and to not use or disclose it for any purposes except as directed by Skooli.
Some of the third parties to whom we may disclose or transfer personal information, may be located outside of Canada, and personal information may therefore be disclosed, transferred, stored (including electronically) or processed outside of Canada for the purposes described herein. By accessing or using our services or otherwise providing information to us, you specifically consent to the processing and transfer of personal information in and to the United States of America ("U.S"). Any personal information which is disclosed, transferred, stored or processed outside of Canada may be subject to legal requirements in foreign countries applicable to Skooli or the applicable third parties, including the United States USA PATRIOT Act of 2001, which facilitates, among other things, the ability of United States of America ("U.S") authorities to conduct searches and to seize or compel the disclosure of records which may contain personal information.
Skooli recognizes that the European Union ("EU") and Switzerland have implemented omnibus data protection regimes established pursuant to the European Data Protection Directive (95/46/EC) and the Swiss Federal Act on Data Protection, respectively. Among other things, these laws require an "adequate level of protection" for the transfer of certain individually identifiable data about individuals in EU member countries and Switzerland to Skooli's operations in Canada. The EU and Switzerland have each recognized that Canada is considered as providing such adequate level of protection pursuant to PIPEDA, with which Skooli complies.
We strive to maintain personal information in as accurate, complete and up-to-date a form as necessary to fulfill the purposes for which it was collected. We protect personal information by security safeguards appropriate to the sensitivity of the personal information, regardless of format. Our security safeguards include premises security and restricted access to files containing personal information. Depending upon the information under our control, we also use technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access, internal passwords and security policies.
We automatically collect certain information about you when you access or use our website or transact business with us, including:
To the extent that our website contains links to third party web sites. Skooli is not responsible for the privacy practices or the content of such web sites nor does Skooli warrant the quality, accuracy or completeness of information contained in these sites.
You may write to our Chief Privacy Officer to request access to personal information about you. Skooli will generally inform you if we are holding personal information about you, as well as details about the personal information. We reserve the right to confirm your identity before complying with any access request. In responding to an access request, we may charge a reasonable copying or retrieval fee, the amount of which we will provide in advance. Access to personal information may be denied if required or authorized by law. If a request for access is denied, Skooli will provide an explanation of the reasons for the refusal.
If you choose to withdraw your consent to continued collection, use or retention of your personal information, we will explain the consequences of such withdrawal. You may also challenge the accuracy of personal information about you in our custody and Skooli will amend personal information where appropriate.
If you wish to request access to personal information about you, request a correction to information
about you or have questions about our privacy policy, you may contact our Privacy Officer as follows:
If you have a concern about the personal information handling practices of Skooli, a complaint, in writing, may be directed to our Privacy Officer. Upon verification of your identity, we will act promptly to investigate the complaint and respond within 60 days.
Where our Privacy Officer makes a determination that a complaint is well founded, we will take the necessary steps to correct the offending information handling practice and/or revise the privacy policies and procedures of Skooli. Where our Privacy Officer determines that a complaint is not well founded, the individual will be notified in writing of such determination.
If you are dissatisfied with the finding of and corresponding action taken by the our Privacy Officer, you
may bring a complaint to the Federal Privacy Commissioner at the address below: