Last Updated: June 17, 2025
We, at Distilled Technologies Inc (trading as Affinity Learning) (“we”, “us”, “our”), respect your privacy and are committed to protecting it by complying with this Privacy Notice. We prepared this Privacy Notice to demonstrate our data handling practices and help you understand what we do as a learning system service provider. This Privacy Notice outlines how we collect, use, share, protect, and otherwise manage your Personal Information when you:
This Privacy Notice also describes your choices when it comes to your Personal Information and your rights. We have benchmarked this Privacy Notice in compliance with Canada's privacy laws.
Please read this Privacy Notice carefully before using our Website and/or Services. By sharing your Personal Information with us, you agree to the practices outlined in this Privacy Notice. If you don't agree, please don't use our Website or provide your Personal Information to us.
Stay Updated
Since our business activities may change and the privacy regulatory landscape may evolve, so might this Privacy Notice. Please review this Privacy Notice from time to time. We will indicate at the top of the Privacy Notice when it was most recently updated and, if the changes are significant, we will provide more prominent notice.
Other Links
Our Website may contain links to other third-party sites. When you click on one of these links, you are visiting a website operated by someone other than us, and the operator of that website may have different privacy policies. We are not responsible for the individual privacy practices of those sites. We encourage you to investigate the privacy policies of these third-party operators.
Affinity Learning is accountable for the Personal Information it collects, uses, or discloses during its commercial activities as described above.
When we provide our Services to other organizations (such as schools or hospitals) to use for their purposes, we may receive access to Personal Information solely to process on their behalf. In these cases, the organization you have a relationship with remains responsible for your Personal Information and determines the purposes for which your information is collected, used or disclosed. In these circumstances, Affinity Learning acts as a service provider to the organization and processes the information under their instructions and in accordance with their privacy policies. If you are a learner or content provider registered with an organization, we will refer your inquiries to that organization, unless your question or concern relates directly to Us.
“Personal Information” in this Privacy Notice is information related to you which could reasonably be used to identify you. It generally does not include business contact information or anonymous/aggregated information which does not identify you.
We have detailed the types of Personal Information we may collect and how we use it below:
| Category of Information | Type of Personal Information | How We Use It |
|---|---|---|
| Account Information | Name, email address, purchase information, student / learner number, and course information and email communication preferences. |
To provide you with login credentials, maintain your learner profile and provide you with Services. To provide you with notices about your account and/or learning content, conduct analytics to enhance your learner experience, and communicate with you about Services or content that we think are relevant to you (with consent where required). |
| Audio Information | Voice recordings. | Certain features of our Services enable voice recording for voice-to-text. We do not use your voice recording to verify or identify you. We use OpenAI to analyze voice recordings from the users of our Services. |
| Payment Information | Payment information, such as your credit card or other payment details used to make payments for the Services, address, and contact information. | To process and verify your purchases, maintain a record of your transactions |
| Non-Personal Information | Information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. | We may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of learners accessing a specific Service feature. This enables us to provide you with an enhanced learner experience and provide aggregated statistics to organizations. |
| Location Information | Address, country, and IP address. | To understand the demographics of our learners and the traffic flow on our Website and platform. |
| Device/Cookie Information | Device identifiers, mobile and web network activity and related information, including IP address, internet service provider, device type, browser type, time zone, browser plug-in types and versions, operating system and platform, or information about your internet connection, and usage details, cookie settings, and location information. (See Section 3.1 to learn more about the use of Cookies). | To make our content available to you, ensure you can interact with our Website and platform properly based on your device, conduct analytics, and for the security of our Website and platform. We also use cookies to better analyze trends, administer our Website and platform, and navigate movement (e.g., peak hours of Website use and which pages were viewed). |
| Legal Information | Fraud alerts and checks raised about your transactions, including payment card declines, suspected criminal activities involving our Services, complaints, claims or accidents reported by you. | To protect our learners, organizations, staff and business from criminal activities and potential risks, fulfill our legal responsibilities, and defend ourselves if necessary. |
| Job Applicant Information | Name, contact details, education history, qualifications, background checks, resume and other employment-related information for application purposes. | To provide you with potential employment. |
| Platform Usage Information | Aggregate data, platform usage. | As a learner on our platform, whether independently or through an affiliated organization, the platform may collect data on your usage when you interact with it and engage in the learning content. Content creators may see your learner reports for learning content you are assigned to, which may disclose your email, student/participant number, and aggregated data on your learner activity. |
We collect your information through methods such as:
Information You Provide to Us
You may voluntarily provide us with Personal Information, such as your name, e-mail address, and company name, when you create an account or engage us on our Website or through our platform.
From Third Parties
We may collect your Personal Information from third parties, such as service providers, or payment processors (last 4 digits only). We use Stripe, Google Analytics, Google Cloud Platform, and OpenAI to help us process Personal Information, provide Services to you and provide a better learner experience.
Information We Automatically Collect
When you visit our Website and/or use our Services, we may receive information about your visit, use, or interactions. We collect this information through “cookies” and similar technologies. See Section 3.1 for more information.
Information Provided by Organizations
If organizations store and process information using our Services, their activity is governed by their own privacy policies. You are encouraged to familiarize yourself with their privacy practices and any policies or notices they have published to understand what information they provide and process within our Services. We do not access this information unless required to provide our Services.
A "cookie" is a data element that a website can send to your browser, which may then be stored on your device. Most browsers accept cookies automatically but can be configured not to accept them or to indicate when a cookie is being sent. See Section 8.1 on how to configure these settings and opt-out of cookie tracking.
We may use the following types of cookies on our Website:
Strictly Necessary Cookies
These essential cookies are necessary to provide you with our services and grant you access to our Website. These cookies cannot be disabled.
Functional Cookies
These cookies allow us to remember your choices on our Website and provide you with enhanced features and personalized content. For example, these cookies can be used to remember your login credentials or preferences on our Website. While functional cookies can be disabled, this may result in less functionality while using our Website.
Performance or Analytics Cookies
These cookies collect anonymous, passive information about how you use our Website, including web pages you visit and links you click. We use the information collected by such cookies to improve and optimize our Website.
Flash Cookies
Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
Web Beacons
Pages of our 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 us, 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).
We do not sell your Personal Information. There are certain circumstances in which we may disclose, transfer, or share your Personal Information with certain third parties (such as with your organization). We limit who we share your Personal Information with and how much information we share. We may share your Personal Information for the following purposes:
We may share Personal Information with our service providers who help improve our Website, such as analytics and search engine tools. Third parties are contractually obligated to keep this data confidential, use it only for the intended purpose, and follow the same privacy standards set out in this policy;
To assist in developing or performing our Services;
As required by law, Personal Information may be transferred to a buyer or successor if we undergo a merger, sale, reorganization, or similar change, including bankruptcy or liquidation.
To third parties to market their products or services to you if you have explicitly consented to these disclosures.
To compile historical purchase information, analytics, and insights;
To process your payments and fulfil purchases;
To assist with marketing services;
With subsidiaries or affiliated companies, or in the event of a merger or acquisition, or a due diligence process as part of a transaction;
Detect, prevent, or otherwise address fraud, security, or technical issues; and/or
If required to comply with relevant laws or respond to subpoenas or warrants served on us or protect/defend the rights of our company, customers, or users of Services.
We may process, store, and transfer your Personal Information outside of the jurisdiction you reside in. For example, our service providers may be located outside of Quebec, Canada or the European Union, and your Personal Information may be subject to the laws of the jurisdiction in which it is stored, which may or may not be as comprehensive as the laws of the jurisdiction in which you reside. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of the area of jurisdiction may be able to obtain access to your Personal Information through the applicable laws.
By submitting your Personal Information or engaging with our Services, you consent to this transfer, storage, or processing.
Your Personal Information will be retained for at least as long as it is necessary to carry out the purposes set out in this Privacy Notice, and subject to applicable laws. Where your information is provided to us by organizations, retention periods would be determined by the organization. We encourage you to reach out to your organization directly to determine their retention periods.
We may de-identify and/or aggregate your Personal Information in such a way that it cannot be used alone or in combination with other information to identify you. We use this information for statistical purposes and to learn about how we can improve the quality of our Services. We may retain this information without time limits to the extent that we have a legitimate and lawful interest in doing so.
Our Website and Services are not intended for individuals under 13 (thirteen) years of age. No one under the age 13 should provide any Personal Information to us. We do not knowingly collect Personal Information from individuals under 13 (thirteen) on our Website. If you believe we have information about an individual under the age of 13 (thirteen) without parental or legal guardian consent, please contact us at [email protected] and we will delete their information.
We created mechanisms to provide you with the following control over your information:
Most browsers accept cookies automatically; however, these settings can be configured not to accept them. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that if you do this, you might not be able to use the full functionality of our Website and/or Services. You can modify these settings at any time.
We fully comply with the requirements of Canada's Anti-Spam Legislation (CASL). A Commercial Electronic Message (CEM) is any message that promotes a product, service, or business. Communication relating to new features or updates of our Services is not considered a CEM under CASL.
If you have opted in to receive certain marketing emails from us but no longer wish to have your contact information used by us to promote our own or third parties' products or services, you can opt out of these communications by sending us an email to unsubscribe at [email protected].
Once you have sent an unsubscribe request, please allow for 10 (ten) days for the request to be processed. If you opt out of marketing communications, we may still send you communications regarding your purchase of our Services.
We use third-party services like Google Analytics to understand how people use our website and to show you ads that match your interests. These services help us measure how learners interact with our ads. The data we collect is aggregated and doesn't identify you personally. When we show you tailored ads, we may use tools like cookies or match your contact info (like email or phone number) with data from those platforms. These third parties may also use their tracking technologies on our site and others to deliver targeted ads.
To opt out of tailored advertising, please visit the Digital Advertising Alliance of Canada Opt-Out Tool at https://youradchoices.ca/en/tools for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
We take steps to protect your Personal Information using physical, technical, and organizational safeguards. Only staff and third parties who need the information to do their jobs can access it. However, no method of sending data over the internet is completely secure. We recommend using strong, unique passwords and keeping them private. Sharing your information online is at your own risk, and we cannot guarantee that our security measures will always prevent unauthorized access. We are not responsible for circumvention of any privacy settings or security measures contained in the Services.
You may have certain rights with respect to the processing of your Personal Information and depending on the jurisdiction within which you reside. This section of the Privacy Notice describes those rights and how you may exercise them should you choose to do so.
Right to Access or Correction: You have the right to access and/or correct your Personal Information. We will consider and respond to requests per applicable laws.
When we receive a written request from you to access or correct your Personal Information, we may ask you for further information to verify your identity. There may be exceptions to your right to access or correct your Personal Information prescribed by law. We will respond to your request for access or correction within a reasonable timeline, in accordance with applicable laws.
Right to Withdraw Consent: If you've given us permission to collect, use, or share your personal information, you may have the right to withdraw that consent in certain situations. To do so, please contact us at [email protected].
Keep in mind that withdrawing your consent might mean we can't provide you with certain Services. If that's the case, we'll explain what the impact will be so you can make an informed decision.
Right to Deletion: Quebec's residents have the right to ask us to delete your Personal Information in certain circumstances. In some instances, such as legal reasons, we will not be able to fulfill your deletion request. If we cannot fulfill your request, we will notify you of the reason.
Right to Data Portability: If you reside in Quebec, you have the right to ask us to transfer your Personal Information to another organization in a structured, commonly used, and machine-readable format.
Right to Lodge a Complaint: You have the right to file a complaint with a supervisory authority or regulator in the jurisdiction where you believe your rights have been violated. If you are concerned about our Personal Information practices, we would appreciate hearing about it first to try to resolve your concerns. You can contact us through the methods listed under Section 11.
If you have any questions, comments or concerns about our privacy practices or how our service providers manage your Personal Information, please contact us at:
Attn: Privacy Officer
[email protected]
20 Camden St, Suite 200
Toronto, ON
M5V 1V1
If you are concerned about your Personal Information, we would appreciate hearing about it first to try and resolve your concerns. If we did not respond satisfactorily to your complaint or inquiry, you have the right to notify the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of
Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: 819-994-6591
www.priv.gc.ca