Privacy Policy
Last Modified: October 18, 2023
Introduction
Distilled Technologies Inc. and our affiliates and subsidiaries ("Company" or "We") respect your privacy and
are committed to protecting it by complying with this policy.
This policy describes:
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How we collect, use, disclose, and protect the personal information of our customers and website users
("you").
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Describes the types of information we may collect from you or that you may provide when you visit the
website affinitylearning.ca (our "Website").
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Describes the types of information we may collect from you or that you may provide when you use our
services, including, but not limited to, our cloud service offerings, Website, and other software
solutions (collectively, our “Services”).
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Our practices for collecting, using, maintaining, protecting, and disclosing that information.
We will only use your personal information in accordance with this policy unless otherwise required by
applicable law. We take steps to ensure that the personal information that we collect about you is adequate,
relevant, not excessive, and used for limited purposes.
Privacy laws in Canada generally define "personal information" as any information about an identifiable
individual, which includes information that can be used on its own or with other information to identify,
contact, or locate a single person. Personal information does not include business contact information,
including your name, student ID, title, or business contact information.
This policy applies to information we collect, use, or disclose about you:
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On this Website.
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In email, text, and other electronic messages between you and this Website.
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Through mobile and desktop applications you download from this Website, which provide dedicated
non-browser-based interaction between you and this Website.
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When you interact with our advertising and applications on third-party websites and services if those
applications or advertising include links to this policy.
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Through applications you use which we provide to you.
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Through our Services, including our cloud services offerings.
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We collect offline or through any other means, including on any other Company or third-party website
(including our affiliates and subsidiaries).
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You provide to or is collected by any third party (including our affiliates and subsidiaries), through
any application or content (including advertising) that may link to or be accessible from or on the
Website.
The Website and Services may include links to third-party websites, plug-ins, services, social networks, or
applications. Clicking on those links or enabling those connections may allow the third party to collect or
share data about you. If you follow a link to a third-party website or engage a third-party plugin, please
note that these third parties have their own privacy policies and we do not accept any responsibility or
liability for these policies. We do not control these third-party websites, and we encourage you to read the
privacy policy of every website you visit.
Please read this policy carefully to understand our policies and practices for collecting, processing, and
storing your information. If you do not agree with our policies and practices, your choice is not to use our
Services. By accessing or using our Services, you indicate that you understand, accept, and consent to the
practices described in this policy. This policy may change from time to time (see Changes to Our Privacy
Policy). Your continued use of our Services after we make changes indicates that you accept and consent to
those changes, so please check the policy periodically for updates. We will notify you in advance of any
material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose
your personal information.
Information We Collect About You
We collect and use several types of information from and about you, including:
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Personal information, that we can reasonably use to directly or indirectly identify you, such as your
name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect
your
computer to the Internet, user name or other similar identifier, billing and account information, and
any
other identifier we may use to contact you ("personal information").
We provide an opportunity for any user to opt-out of contact for marketing purposes on an ongoing basis
by
e-mailing to [email protected].
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Non-personal 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.
Statistical or aggregated data does not directly identify a specific person, but we may derive
non-personal
statistical or aggregated data from personal information. For example, we may aggregate personal
information
to calculate the percentage of users accessing a specific Service feature.
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Technical information, including your login information, browser type and version, time zone setting,
browser plug-in types and versions, operating system and platform, or information about your internet
connection, the equipment you use to access our Services, and usage details.
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Non-personal details about your interactions, including the full Uniform Resource Locators (URLs),
clickstream to, through and from our Website (including date and time), products you viewed or searched
for,
page response times, download errors, length of visits to certain pages, page interaction information
(such
as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number
used
to call our customer service number.
How We Collect Information About You
We use different methods to collect your information, including through:
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Direct interactions with you when you provide it to us, for example, by filling in forms or
corresponding with us by phone, email, or otherwise.
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Automated technologies or interactions, as you navigate through our Services. Information collected
automatically may include usage details, IP addresses, and information collected through cookies, web
beacons, and other tracking technologies.
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Third parties or publicly available sources, for example, our business partners.
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Google Analytics allows us to keep our website relevant by helping us understand how people use the
Website. The information collected by Google Analytics is anonymous and only used for statistical
purposes,
and it helps us to analyse patterns of user activity and to develop a better user experience. Google
Analytics cookies do not provide us with any Personal Information.
Information You Provide to Us
The information we collect directly from you on or through our Services may include:
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Information that you provide by filling in forms on our Website. This includes information provided at
the
time of registering to use our Website, subscribing to our service, posting material, and requesting
further
services. We may also ask you for information when you enter a contest or promotion sponsored by us, and
when you report a problem with our Website.
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Records and copies of your correspondence (including email addresses), if you contact us.
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Your responses to surveys that we might ask you to complete for research purposes.
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Details of transactions you carry out through our Services and of the fulfillment of your orders. You
may
be required to provide financial information before placing an order through our Services.
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Your search queries using our Services.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Services, we may use cookies or other automatic data
collection technologies to collect certain information about your equipment, browsing actions, and patterns,
including:
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Details of your visits to our Services, including traffic data, location data, logs, and other
communication data and the resources that you access and use through our Services.
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Information about your computer and internet connection, including your IP address, operating system,
and
browser type.
We may also use these technologies to collect information about your online activities over time and across
third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored
advertising please visit 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.
The information we collect automatically is statistical data and does not include personal information, and
we may maintain it or associate it with personal information we collect in other ways, that you provide to
us, or receive from third parties. It helps us to improve our Website and Services and to deliver a better
and more personalized service, including by enabling us to:
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Estimate our audience size and usage patterns.
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Store information about your preferences, allowing us to customize our Services according to your
individual interests.
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Speed up your searches.
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Recognize you when you return to our Services.
The technologies we use for this automatic data collection may include:
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Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You
may
refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you
select this setting you may be unable to access certain parts of our Website. Unless you have adjusted
your
browser setting so that it will refuse cookies, our system will issue cookies when you direct your
browser
to our Website.
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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. For information about
managing
your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your
Information.
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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 the Company, 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).
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications on our Services, including advertisements, are served by third-parties,
including advertisers, ad networks and servers, content providers, and application providers. These third
parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect
information about you when you use our Services. The information they collect may be associated with your
personal information or they may collect information, including personal information, about your online
activities over time and across different websites and other online services. They may use this information
to provide you with interest-based (behavioural) advertising or other targeted content.
You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out
tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network
Advertising Initiative. You can also access these websites to learn more about online behavioural
advertising and how to stop websites from placing cookies on your device. Opting out of a network does not
mean you will no longer receive online advertising. It does mean that the network from which you opted out
will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties' tracking technologies or how they are used. If you have any questions
about an advertisement or other targeted content, you should contact the responsible provider directly. For
more information about how you can opt out of receiving targeted advertising from many providers, see
Choices About How We Use and Disclose Your Information.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
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To present our Services and its contents to you.
- To provide you with information, products, or services that you request from us.
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To fulfill the purposes for which you provided the information or that were described when it was
collected, or any other purpose for which you provide it.
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To provide you with notices about your account, including expiration and renewal notices.
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To provide you with notices about your subscription, including expiration and renewal notices.
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To carry out our obligations and enforce our rights arising from any contracts with you, including for
billing and collection or to comply with legal requirements.
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To notify you about changes to our Website or any products or services we offer or provide though it.
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To improve our Website, products or services, marketing, or customer relationships and experiences.
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To allow you to participate in interactive features, social media, or similar features on our Services.
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To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver
relevant advertising to you.
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In any other way we may describe when you provide the information.
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For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties' goods and services that may
be of interest to you, as permitted by law. If you do not want us to use your information in this way,
please e-mail us at
[email protected]. For more information, see Choices About How We Use and
Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our
advertisers' target audiences. Even though we do not disclose your personal information for these purposes
without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume
that you meet its target criteria.
Disclosure Of Your Information
We may disclose aggregated information about our users, and information that does not identify any
individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
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To our subsidiaries and affiliates.
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In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's
assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in
which
personal information held by the Company about our customers and users is among the assets transferred.
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To third parties to market their products or services to you if you have consented to these disclosures.
For more information, see Choices About How We Use and Disclose Your Information.
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To contractors, service providers, and other third parties we use to support our business (such as
analytics and search engine providers that assist us with Website improvement and optimization) and who
are
contractually obligated to keep personal information confidential, use it only for the purposes for
which we
disclose it to them, and to process the personal information with the same standards set out in this
policy.
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To fulfill the purpose for which you provide it.
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For any other purpose disclosed by us when you provide the information.
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With your consent.
We may also disclose your personal information:
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To comply with any court order, law, or legal process, including to respond to any government or
regulatory request, in accordance with applicable law.
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To enforce or apply our terms of use, and other agreements, including for billing and collection
purposes.
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If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the
Company, our customers, or others. This includes exchanging information with other companies and
organizations for the purposes of fraud protection and credit risk reduction.
Transferring Your Personal Information
We may transfer personal information that we collect or that you provide as described in this policy to
contractors, service providers, and other third parties we use to support our business (such as analytics
and search engine providers that assist us with Services improvement and optimization) and who are
contractually obligated to keep personal information confidential, use it only for the purposes for which we
disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different
privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the
governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to
your personal information through the laws of the foreign country.
By submitting your personal information or engaging with our Services, you consent to this transfer,
storage, or processing.
Choices About How We Use And Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created
mechanisms to provide you with the following control over your information:
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Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies,
or
to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts
of this Website may not be accessible or may not function properly. For more information about tracking
technologies, see Information We Collect Through Cookies and Other Automatic Data Collection
Technologies.
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Promotional Offers from the Company. If you have opted in to receive certain emails from us but no
longer
wish to have your contact information used by the Company to promote our own or third parties' products
or
services, you can opt-out by sending us an email stating your request to [email protected].
If we
have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included
in
the email. This opt-out does not apply to information provided to the Company as part of a product
purchase,
warranty registration, product service experience, or other transactions.
We do not control third parties' collection or use of your information to serve interest-based
advertising.
However, these third parties may provide you with ways to choose not to have your information collected
or
used in this way. You can opt out of several third party ad servers' and networks' cookies
simultaneously by
using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created
by
the Network Advertising Initiative. You can also access these websites to learn more about online
behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a
network does not mean you will no longer receive online advertising. It does mean that the network from
which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
Data Security
The security of your personal information is very important to us. We use physical, electronic, and
administrative measures designed to secure your personal information from accidental loss and from
unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have
chosen) a password for access to certain parts of our Services, you are responsible for keeping this
password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our
best to protect your personal information, we cannot guarantee the security of your personal information
transmitted to our Services. Any transmission of personal information is at your own risk. We are not
responsible for circumvention of any privacy settings or security measures contained in the Services.
Data Retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal
information for as long as necessary to fulfill the purposes we collected it for, including for the purposes
of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize
your personal information so that it can no longer be associated with you. We reserve the right to use such
anonymous and de-identified data for any legitimate business purpose without further notice to you or your
consent.
Children Under The Age Of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any
information to or on the Services. We do not knowingly collect personal information from children under 13.
If you are under 13, do not use or provide any information on this Website or on or through any of its
features, make any purchases through the Website, or provide any information about yourself to us, including
your name, address, telephone number, email address, or any screen name or user name you may use. If we
learn we have collected or received personal information from a child under 13 without verification of
parental consent, we will delete that information. If you believe we might have any information from or
about a child under 13, please contact us at
[email protected]
Accessing And Correcting Your Personal Information
It is important that the personal information we hold about you is accurate and current. Please keep us
informed if your personal information changes. By law you have the right to request access to and to correct
the personal information that we hold about you.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may
also send us an email at
[email protected] to request access to, correct, or delete any personal
information that you have provided to us. We may not accommodate a request to change information if we
believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and
to provide you with the personal information that we hold about you or make your requested changes.
Applicable law may allow or require us to refuse to provide you with access to some or all of the personal
information that we hold about you, or we may have destroyed, erased, or made your personal information
anonymous in accordance with our record retention obligations and practices. If we cannot provide you with
access to your personal information, we will inform you of the reasons why, subject to any legal or
regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy
legislation. Examples of such exceptions include:
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Information protected by solicitor-client privilege.
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Information that is part of a formal dispute resolution process.
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Information that is about another individual that would reveal their personal information or
confidential
commercial information.
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Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact
our Privacy Officer at
[email protected].
Withdrawing Your Consent
Where you have provided your consent to the collection, use, and transfer of your personal information, you
may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if
applicable, contact us at
[email protected]. Please note that if you withdraw your consent we may
not be able to provide you with a particular product or service. We will explain the impact to you at the
time to help you with your decision.
Changes To Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes
to how we treat our users' personal information, we will notify you through a notice on the Website home
page. We include the date the privacy policy was last revised at the top of the page. You are responsible for
ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting
our Website and this privacy policy to check for any changes.
Contact Information And Challenging Compliance
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices.
Please contact us at:
Privacy Officer
[email protected]
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal
information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance
with this policy please contact our Privacy Officer using the contact information listed above.
You may also make a complaint about our information and privacy practices to the Information and Privacy
Commissioner at:
Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, QC K1A 1H3
1 (800) 282-1376