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Privacy Policy

CONSENT

Use of the DISTIL Interactive Ltd. ("DISTIL") website, products or services indicates consent and agreement to be bound by this privacy policy. If DISTIL wishes to use or disclose personal information other than as described in this Privacy Policy, DISTIL will obtain an end-user's express consent before doing so.

Consent includes agreeing to the transfer of the personal information to Canada and the collection and processing of the information there and in other countries. End users should not use the DISTIL website or the DISTIL training software if they do not agree with this privacy policy.

This privacy policy applies to all personal information obtained by DISTIL from end-users or through end-users' use of DISTIL products or services. "Personal Information" means information about an identifiable individual with the exception of business contact information such as job title or work-related telephone number or postal address.

INFORMATION DISTIL COLLECTS AND HOW IT IS USED

WEBSITE AND SERVERS

Through its website, DISTIL provides and collects cookies, small files containing a string of characters to uniquely identify an end-user's browser. DISTIL uses cookies to identify website users, to ensure no one else can login simultaneously with the same username account, to allow automated sign-in of an end user, or to track an end user's use of the website. DISTIL may also collect cookies and an end-user's system information such as operating system and platform, browser type and language, date, time, connection speed and IP address for the purposes of maintaining and improving its delivery of services and the security of its systems.

COMMUNICATIONS AND ORDERS

In the event an end user communicates with DISTIL or a third party contractor for DISTIL, by phone, e-mail, or otherwise, DISTIL may collect the end-user's name, address, telephone number, e-mail address, credit card information, financial information, username and password, survey information, and the names of products that the end-user has used or wishes to use.  DISTIL will use this information to process and fulfill orders, resolve disputes, provide technical support related to its products and services, and to provide marketing information to end-users. Information required for processing and fulfilling orders will be shared with contractors used by DISTIL to perform such services, and with financial institutions as required. End-users may opt out of DISTIL's marketing communications.

TRAINING SOFTWARE

Through the training software, DISTIL collects and uses the following information:

  1. a username and password to provide access to the software;
  2. during an end-user's performance in the software, data is collected with respect to the end-user's behaviour within the software and logged for the purposes of assessment;
  3. after performing an assessment of the end-user's performance, DISTIL associates the assessment with the end-user's personal information and the name of the training software to create a report;
  4. DISTIL provides the report to (i) the purchaser of the end-user's license to use the training software; (ii) a training body or accreditation body for which the purchaser of the license wishes a report to be sent; (iii) if the end user requests an appeal of an assessment, to a person who conducts such appeals according to DISTIL's appeals policy if any; and (iv) such other entity as requested by the end-user;
  5. the end-user's personal information, behaviour log and assessment will be retained to allow an appeal of the assessment, to allow an end-user to request a report be sent to another entity, and to facilitate future purchases by the end-user;
  6. the end-user's behaviour log will be added to an assessment database of behaviour logs to improve the database's performance, and to permit demographic analysis by DISTIL for the development or improvement of products; and
  7. DISTIL compiles aggregate performance statistics excluding personally-identifiable information to provide to training bodies, accreditation bodies, and other entities wishing to assess the relative success of training efforts.

OTHER DISCLOSURE

DISTIL may share personal information with a third party

  1. that merges with or acquires DISTIL or acquires the assets of DISTIL;
  2. that is a subsidiary, affiliated company or trusted person for the purpose of processing information on DISTIL's behalf in compliance with our privacy and confidentiality requirements; and
  3. where DISTIL in good faith believes it is necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request, (ii) enforce applicable product or service terms, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, or (iv) protect against imminent harm to the rights, property or safety of DISTIL, its licensors, its users or the public as required or permitted by law.

SAFEGUARDS

DISTIL stores personal information on password-protected computer servers located in a facility with controlled physical access. DISTIL USES COMMERCIALLY REASONABLE SECURITY PRECAUTIONS TO PROTECT PERSONAL INFORMATION BUT BECAUSE IT OPERATES OVER THE INTERNET, IT CANNOT GUARANTEE THAT PERSONAL INFORMATION WILL BE FREE FROM UNAUTHORIZED ACCESS. DISTIL DISCLAIMS ANY LIABILITY FOR ANY THEFT OR LOSS OF, UNAUTHORIZED ACCESS OR DAMAGE TO, OR INTERCEPTION OF ANY DATA OR COMMUNICATIONS. Any personal information supplied by e-mail or other unsecured means is done at the end-user's risk.

CHECKING AND UPDATING PERSONAL INFORMATION

Upon reasonable request, end users can check their personal information at DISTIL:

  1. to correct or update personal information;
  2. to request deletion of personal information if it is not otherwise required to be retained by law or for legitimate business purposes; or
  3. to request that DISTIL stop providing marketing communications.

To make a request, end-users may be required to identify themselves and the information to be checked or updated, and DISTIL may decline to process requests that are unreasonably repetitive or require disproportionate effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests related to backup tapes), or for which access is not otherwise required. DISTIL will respond to reasonable requests to check and update personal information free of charge.

CONTACT

Inquiries related to the privacy policy may be directed to privacy@distilinteractive.com or in writing to Attn: Privacy Officer, DISTIL Interactive Ltd., 16 Fitzgerald Road, Suite 200, Ottawa ON Canada K2H 8R6

To opt out of marketing communications, reply to the sender with "unsubscribe" in the subject or email privacy@distilinteractive.com requesting to be unsubscribed.

REVISIONS

This privacy policy may be revised from time to time and the current policy applies to all information that DISTIL collects. The current policy will be displayed on the DISTIL website. DISTIL will not materially change the privacy policy to make it less protective of information collected in the past without the consent of affected end users.