ReThink Ability Privacy Policy
ReThink Ability (“ReThink Ability”, “we”, “us” or “our”) values the privacy of individuals or entities (“users”, “you”, or “your”) who visits our web sites, including but not limited to www.ReThinkAbility.ca (“Website”, or ”Site”) and uses our services, including but not limited ReThink Ability (“Services”, or “Program”) and we take steps intended to meet our privacy obligations with respect to personal information under applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act. The purpose of this Privacy Policy is to inform you about what and how we collect, use, disclose and protect your personal information.
Personal information is information about an identifiable individual as particularly described under provincial and federal privacy legislation. This Privacy Policy applies to our collection, use and disclosure of personal information in Canada.
Terms of Use
By accessing or using the Site and Services in any manner, you also agree to be bound by Rethink Ability’s Terms of Service (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Site or Services.
Our Legal Basis for Collecting Personal Information
Whenever we collect Personal Information from you, we may do so on the following legal bases:
- Your consent to such collection and use;
- Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Products;
- Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
- Intra-organization transfers for client data for administrative purposes;
- Product development and enhancement, where the processing enables Rethink Ability to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our users, and to better understand how people interact with our Sites;
- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
What personal information do we collect?
We collect personal information from you when you register for training, request information, or complete a survey using our website. Personal information may include full name, address, email address, digital identity (such as login name or handle), information about your device, telephone number and other information that we collect with your consent or as we are required or permitted to collect by law.
Workplace and School Provided Information.
Others engaging our services for your use, such as your employer or your school, provide us with personal data and your eligibility to the use their Services that they purchase for use by their workers or students. The information provided by your employer or school may include your name and phone number.
What do we use your personal information for?
Any of the personal information we collect from you may be used for one of the following purposes:
To personalize and improve your experience;
To authorize access to our Sites and Services;
To provide Services and Products (for instance, training requests);
To offer and administer programs;
To administer content, promotion, sweepstakes, surveys, voting polls, or other Site features as may arise (which may include periodic emails to your account with unsubscribe instructions at the bottom of each email);
To respond to and support users regarding their use of the Site and Services;
To investigate possible fraud or other violations of our Terms of Service or this Privacy Policy and/or attempts to harm our Users;
To meet our legal, regulatory, insurance, security, and processing requirements; and
Otherwise, with your consent or as we are required or permitted by law.
User Accounts
Through ReThink Ability’s learning management platform, you register and create a User Account. A User Account is stored information that we keep on individual users detailing their viewing preferences, activities, and interactions. You may review and edit your User Account information, or delete your User Account, at any time. To open a User Account, or purchase items and services through ReThink Ability, you will be required to provide personal information.
Payments
Credit card information is transmitted to a third-party payment gateway provider and is not retained by ReThink Ability. To complete the payment transaction, you leave the ReThink Ability site.
Information transferred to our payment gateway provider’s database is maintained in accordance with that organization’s privacy policy.
Authorized employees, third party service providers, agents and mandataries of ReThink Ability who require access to your personal information to fulfill the purpose for which the information was collected will have access to your personal information.
Third Party Links
This Privacy Policy applies only to ReThink Ability. ReThink Ability may share links to other websites not operated or controlled by us. The policies and procedures we describe here do not apply to these websites. Sharing the links does not imply that we endorse or have reviewed these websites. We suggest contacting those sites directly for information on their privacy policies.
Do we disclose your personal information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personal information except as described in this Privacy Policy.
Third Parties. We may transfer personal information to outside third-party service providers or agents who act on our behalf to assist us in operating our website, conducting our business, or providing services to you for the purposes described in this Privacy Policy.
Enterprise Accounts. Your employer or school may offer you access to our Services. We will share personal date with your employer or school. Your employer or school can review and manager your use of such enterprise Services. We may also release your information to your employer, if your enrollment is through a corporate agreement and disclosure is needed to comply with the employer’s request for information, and to any third party administrator, if your enrollment is through this third party administrator’s request for information.
Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Information about our users is often a transferred business asset. In the event that ReThink Ablity NB itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.
Aggregate Site Use Information. We may share aggregate and anonymized/pseudonymized Personal Information to third parties in order to promote or describe use of the Sites, for research, marketing, advertising, or similar purposes.
We take reasonable contractual or other measures to ensure that these parties agree to keep your personal information confidential and to comply with applicable privacy legislation.
We may disclose your personal information when we believe disclosure is required to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety.
We may disclose aggregate, non-personally identifiable information to other parties for marketing, advertising, or other uses.
How do we protect your personal information?
We take reasonable security measures to maintain the safety of your personal information in our custody and control. These measures include using physical, electronic, and organizational/procedural security measures appropriate to the sensitivity of the information. This includes safeguards to protect against loss, theft, unauthorized access, use, disclosure, copying or modification.
We may retain your Personal Information for a period of time consistent with the original purpose for collection. We may also retain your Personal Information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
We retain your Personal Information even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.
Do we use cookies?
Yes, we do. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.
We use cookies to understand and save your preferences (such as which language you want to access content in) for future visits, and to compile aggregate non-personally identifiable data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly.
Your Consent
We generally collect, use, or disclose your personal information with consent or as we are required or allowed to do by law, for example to comply with a court order or a statute or regulation or to collect a debt owed to us.
Your consent to our collection, use or disclosure of your personal information may be implied or express. For example, you may expressly agree to certain types of collection, use or disclosure by electronically clicking a button when the purpose of the collection, use or disclosure is described at the time of collection. You may implicitly consent to the collection, use or disclosure of personal information when you provide that information to receive a requested service or product.
By using our website and by providing us with your personal information, we will assume that you consent to the collection, use and disclosure of such information for the purposes that are described in this Privacy Policy.
Children
The Site is not intended for use by children. We do not intentionally gather Personal Information about visitors who are under the age of majority. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under the age of majority in the applicable jurisdiction, please contact us at admin@rethinkability.ca. If we learn that we have inadvertently collected the personal information of a child under the age of majority, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
Our Opt-in/Opt-out Policy
By providing an email address on the Rethink Ability Sites, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any service related notices, or to provide you with information about our events, invitations, or related educational information.
For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be.
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
- At any time, you can contact us through admin@rethinkability.ca or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Information.
Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.
Third Party Links
The Sites may contain links to webpages operated by parties other than Rethink Ability. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Rethink Ability strongly recommends that each User review the third party’s terms and policies.
Changes to our Privacy Policy
This Privacy Policy may be revised from time to time. If we decide to change our Privacy Policy, we will post those changes on this page, and/or update the Privacy Policy modification date below. You should access and review this Privacy Policy frequently to ensure that you are aware of the most current version.
This policy was last modified on January 21, 2022.
Contacting Us
If you have any questions regarding this Privacy Policy or wish to access or correct your personal information in the custody or control of Rethink Ability, you may contact us using the information below.
ReThink Ability
Administrative support
Call: 506.459.7852 (c/o LDANB)
Email: admin@rethinkability.ca