Last updated: September 14, 2020
This Privacy Policy describes Our policies and procedures
on
the
collection, use and disclosure of Your information when You use the Service and
tells
You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the
Service.
By
using the Service, You
agree to the collection and use of information in accordance with this Privacy
Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have
meanings defined under the
following conditions. The following definitions shall have the same meaning
regardless
of
whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Account
means a unique account created for You to access our Service or parts of our
Service.
Business,
for the purpose of the CCPA (California Consumer Privacy Act), refers to the
Company as the legal entity that collects Consumers" personal information and
determines the
purposes and means of the processing of Consumers" personal information, or on
behalf of
which such information is collected and that alone, or jointly with others,
determines the
purposes and means of the processing of consumers" personal information, that
does
business
in the State of California.
Company
(referred to as either "the Company", "We", "Us" or "Our" in this Agreement)
refers
to Toronto Mandarin School, Inc., 200 Consumers Rd., Suite 410, North York, ON
M2J
4R4.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a
natural
person who is a California resident. A resident, as defined in the law, includes
(1)
every
individual who is in the USA for other than a temporary or transitory purpose,
and
(2) every
individual who is domiciled in the USA who is outside the USA for a temporary or
transitory
purpose.
Cookies
are small files that are placed on Your computer, mobile device or any other
device
by a website, containing the details of Your browsing history on that website
among
its many
uses.
Country
refers to: Ontario, Canada
Device
means any device that can access the Service such as a computer, a cellphone or a
digital tablet.
Do Not Track (DNT)
is a concept that has been promoted by US regulatory authorities, in
particular the U.S. Federal Trade Commission (FTC), for the Internet industry to
develop and
implement a mechanism for allowing internet users to control the tracking of
their
online
activities across websites.
Personal Data
is any information that relates to an identified or identifiable individual.
For the purposes of the CCPA, Personal Data means any information that
identifies,
relates
to, describes or is capable of being associated with, or could reasonably be
linked,
directly or indirectly, with You.
Sale,
for the purpose of the CCPA (California Consumer Privacy Act), means selling,
renting,
releasing, disclosing, disseminating, making available, transferring, or
otherwise
communicating orally, in writing, or by electronic or other means, a Consumer"s
Personal
information to another business or a third party for monetary or other valuable
consideration.
Service refers to the Website.
Service Provider means any natural or legal person who processes the
data on behalf of the
Company. It refers to third-party companies or individuals employed by the
Company
to
facilitate the Service, to provide the Service on behalf of the Company, to
perform
services
related to the Service or to assist the Company in analyzing how the Service is
used.
Third-party Social Media Service refers to any website or any social
network website through
which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use
of
the
Service or from the Service infrastructure itself (for example, the duration of
a
page
visit).
Website refers to Toronto Mandarin School, accessible from
https://torontomandarinschool.com/
You means the individual accessing or using the Service, or the company,
or other legal
entity on behalf of which such individual is accessing or using the Service, as
applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with
certain personally identifiable
information that can be used to contact or identify You. Personally identifiable
information
may include, but is not limited to:
•
Email address
•
First name and last name
•
Phone number
•
Address, State, Province, ZIP/Postal code, City
•
Bank account information in order to pay for products and/or services within the
Service
•
Usage Data
When You pay for a product and/or a service via bank transfer, We may ask You to
provide
information to facilitate this transaction and to verify Your identity. Such
information
may
include, without limitation:
•
Date of birth
•
Passport or National ID card
•
Bank card statement
•
Other information linking You to an address
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device"s Internet Protocol address
(e.g.
IP
address), browser type, browser version, the pages of our Service that You visit,
the
time
and date of Your visit, the time spent on those pages, unique device identifiers and
other
diagnostic data.
When You access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile device
You
use,
Your mobile device unique ID, the IP address of Your mobile device, Your mobile
operating
system, the type of mobile Internet browser You use, unique device identifiers and
other
diagnostic data.
We may also collect information that Your browser sends whenever You visit our
Service
or
when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our
Service
and
store certain information. Tracking technologies used are beacons, tags, and scripts
to
collect and track information and to improve and analyze Our Service.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is
being
sent. However, if You do not accept Cookies, You may not be able to use some parts
of
our
Service.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your
personal
computer or mobile device when You go offline, while Session Cookies are deleted as
soon
as
You close your web browser. Learn more about cookies: All About Cookies.
We use both session and persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available
through
the
Website and to enable You to use some of its features. They help to authenticate
users and
prevent fraudulent use of user accounts. Without these Cookies, the services
that
You have
asked for cannot be provided, and We only use these Cookies to provide You with
those
services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the
Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the
Website, such
as remembering your login details or language preference. The purpose of these
Cookies is to
provide You with a more personal experience and to avoid You having to re-enter
your
preferences every time You use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the
Website
and how
users use the Website. The information gathered via these Cookies may directly
or
indirectly
identify you as an individual visitor. This is because the information collected
is
typically linked to a pseudonymous identifier associated with the device you use
to
access
the Website. We may also use these Cookies to test new pages, features or new
functionality
of the Website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies,
please
visit our Cookies Policy or the Cookies section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
• To provide and maintain our Service,
including to monitor the usage of our Service.
• To manage Your Account:
to manage Your registration as a user of the Service. The Personal
Data You provide can give You access to different functionalities of the Service
that
are
available to You as a registered user.
• For the performance of a contract: the development, compliance and
undertaking of the
purchase contract for the products, items or services You have purchased or of any
other
contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms
of electronic communication, such as a mobile application"s push notifications
regarding
updates or informative communications related to the functionalities, products or
contracted
services, including the security updates, when necessary or reasonable for their
implementation.
• To provide You with news, special offers and general information about
other goods,
services and events which we offer that are similar to those that you have already
purchased
or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
We may share your personal information in the following situations:
• With Service Providers: We may share Your personal information with
Service Providers to
monitor and analyze the use of our Service, to advertise on third party websites to
You
after You visited our Service, for payment processing, to contact You.
• For Business transfers: We may share or transfer Your personal information
in connection
with, or during negotiations of, any merger, sale of Company assets, financing, or
acquisition of all or a portion of our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in
which case we will
require those affiliates to honor this Privacy Policy. Affiliates include Our parent
company
and any other subsidiaries, joint venture partners or other companies that We
control or
that are under common control with Us.
• With Business partners: We may share Your information with Our business
partners to offer
You certain products, services or promotions.
• With other users: when You share personal information or otherwise
interact in the public
areas with other users, such information may be viewed by all users and may be
publicly
distributed outside. If You interact with other users or register through a
Third-Party
Social Media Service, Your contacts on the Third-Party Social Media Service may see
Your
name, profile, pictures and description of Your activity. Similarly, other users
will be
able to view descriptions of Your activity, communicate with You and view Your
profile.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the
purposes
set out in this Privacy Policy. We will retain and use Your Personal Data to the
extent
necessary to comply with our legal obligations (for example, if we are required to
retain
your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data
is
generally retained for a shorter period of time, except when this data is used to
strengthen
the security or to improve the functionality of Our Service, or We are legally
obligated
to
retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company"s operating
offices
and in any other places where the parties involved in the processing are located. It
means
that this information may be transferred to — and maintained on — computers located
outside
of Your state, province, country or other governmental jurisdiction where the data
protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information
represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is
treated
securely and in accordance with this Privacy Policy and no transfer of Your Personal
Data
will take place to an organization or a country unless there are adequate controls
in
place
including the security of Your data and other personal information.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal
Data
may be
transferred. We will provide notice before Your Personal Data is transferred and
becomes
subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal
Data
if
required to do so by law or in response to valid requests by public authorities
(e.g. a
court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good
faith
belief that such action is
necessary to:
• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method
of
transmission over the Internet, or method of electronic storage is 100% secure.
While We
strive to use commercially acceptable means to protect Your Personal Data, We cannot
guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform their tasks on
Our
behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service providers to monitor and analyze the use of our
Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and
reports
website traffic. Google uses the data collected to track and monitor the use of our
Service.
This data is shared with other Google services. Google may use the collected data to
contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google
Analytics by
installing the Google Analytics opt-out browser add-on. The add-on prevents the
Google
Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with
Google
Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google
Privacy
&
Terms web page: https://policies.google.com/privacy
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or
promotional
materials and other information that may be of interest to You. You may opt-out of
receiving
any, or all, of these communications from Us by following the unsubscribe link or
instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
Mailchimp
Mailchimp is an email marketing sending service provided by The Rocket Science
Group LLC.
For more information on the privacy practices of Mailchimp, please visit their
Privacy
policy: https://mailchimp.com/legal/privacy/
ConvertKit
Their Privacy Policy can be viewed at https://convertkit.com/privacy
Payments
We may provide paid products and/or services within the Service. In that case, we
may
use
third-party services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided
directly to Our third-party payment processors whose use of Your personal
information is
governed by their Privacy Policy. These payment processors adhere to the standards
set
by
PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of
brands
like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help
ensure
the
secure handling of payment information.
PayPal
Their Privacy Policy can be viewed at
https://www.paypal.com/webapps/mpp/ua/privacy-full
WeChat
Their Privacy Policy can be viewed at
https://www.wechat.com/en/privacy_policy.html
TD Online Mart
Their Privacy Policy can be viewed at
https://www.td.com/privacy-and-security/privacy-and-security/our-privacy-commitments/td-privacy-highlights/index.jsp
When You use Our Service to pay a product and/or service
via
bank transfer, We may ask You
to provide information to facilitate this transaction and to verify Your
identity.
Behavioral Remarketing
The Company uses remarketing services to advertise on third
party websites to You after You
visited our Service. We and Our third-party vendors use cookies to inform, optimize
and
serve ads based on Your past visits to our Service.
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise
the
Google Display Network ads by visiting the Google Ads Settings page:
http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on
-
https://tools.google.com/dlpage/gaoptout - for your web browser. Google
Analytics
Opt-out
Browser Add-on provides visitors with the ability to prevent their data from
being
collected
and used by Google Analytics.
For more information on the privacy practices of Google,
please visit the Google Privacy & Terms web page:
https://policies.google.com/privacy
Facebook
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting
this
page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook"s interest-based ads, follow these instructions
from
Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural
Advertising established by the Digital Advertising Alliance. You can also
opt-out
from Facebook and other participating companies through the Digital
Advertising
Alliance in the USA http://www.aboutads.info/choices/, the Digital
Advertising
Alliance of Canada in Canada http://youradchoices.ca/ or the European
Interactive
Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or
opt-
out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit
Facebook"s
Data Policy: https://www.facebook.com/privacy/explanation
CCPA Privacy
Your Rights under the CCPA
Under this Privacy Policy, and by law if You are a resident
of
California, You have the
following rights:
• The right to notice. You must be properly notified which categories of
Personal Data are
being collected and the purposes for which the Personal Data is being used.
• The right to access / the right to request. The CCPA permits You to request
and obtain
from the Company information regarding the disclosure of Your Personal Data that has
been
collected in the past 12 months by the Company or its subsidiaries to a third-party
for
the
third party"s direct marketing purposes.
• The right to say no to the sale of Personal Data. You also have the right
to ask the
Company not to sell Your Personal Data to third parties. You can submit such a
request
by
visiting our "Do Not Sell My Personal Information" section or web page.
• The right to know about Your Personal Data. You have the right to request
and obtain from
the Company information regarding the disclosure of the following:
•
The categories of Personal Data collected
•
The sources from which the Personal Data was collected
•
The business or commercial purpose for collecting or selling the Personal Data
•
Categories of third parties with whom We share Personal Data
•
The specific pieces of Personal Data we collected about You
• The right to delete Personal Data.
You also have the right to request the deletion of Your
Personal Data that have been collected in the past 12 months.
• The right not to be discriminated against.
You have the right not to be discriminated
against for exercising any of Your Consumer"s rights, including by:
•
Denying goods or services to You
•
Charging different prices or rates for goods or services, including the use of
discounts
or other benefits or imposing penalties
•
Providing a different level or quality of goods or services to You
•
Suggesting that You will receive a different price or rate for goods or services
or
a
different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you are a California
resident, You can email or call us or visit our "Do Not Sell My Personal
Information"
section or web page.
The Company will disclose and deliver the required information free of charge within
45
days
of receiving Your verifiable request. The time period to provide the required
information
may be extended once by an additional 45 days when reasonable necessary and with
prior
notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service
Providers we partner with (for
example, our advertising partners) may use technology on the Service that "sells"
personal
information as defined by the CCPA law.
If you wish to opt out of the use of your personal
information
for interest-based
advertising purposes and these potential sales as defined under CCPA law, you may do
so
by
following the instructions below.
Please note that any opt out is specific to the browser You
use.
You may need to opt out on
every browser that you use.
Website
You can opt out of receiving ads that are personalized as
served by our Service Providers by
following our instructions presented on the Service:
•
From Our "Cookie Consent" notice banner
•
Or from Our "CCPA Opt-out" notice banner
•
Or from Our "Do Not Sell My Personal Information" notice banner
•
Or from Our "Do Not Sell My Personal Information" link
The opt out will place a cookie on Your computer that is unique to the browser You
use
to
opt out. If you change browsers or delete the cookies saved by your browser, you
will
need
to opt out again.
Mobile Devices
Your mobile device may give you the ability to opt out of the use of information
about
the
apps you use in order to serve you ads that are targeted to your interests:
•
"Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android
devices
•
"Limit Ad Tracking" on iOS devices
You can also stop the collection of location information
from
Your mobile device by changing
the preferences on your mobile device.
"Do Not Track" Policy as Required by California Online Privacy
Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your
browsing activities. If You are
visiting such websites, You can set Your preferences in Your web browser to inform
websites
that You do not want to be tracked. You can enable or disable DNT by visiting the
preferences or settings page of Your web browser.
Children"s Privacy
The Service may contain content appropriate for children
under
the age of 13. As a parent,
you should know that through the Service children under the age of 13 may
participate in
activities that involve the collection or use of personal information. We use
reasonable
efforts to ensure that before we collect any personal information from a child, the
child"s
parent receives notice of and consents to our personal information practices.
We also may limit how We collect, use, and store some of the information of Users
between 13
and 18 years old. In some cases, this means We will be unable to provide certain
functionality of the Service to these Users. If We need to rely on consent as a
legal
basis
for processing Your information and Your country requires consent from a parent, We
may
require Your parent"s consent before We collect and use that information.
We may ask a User to verify its date of birth before collecting any personal
information
from them. If the User is under the age of 13, the Service will be either blocked or
redirected to a parental consent process.
Information Collected from Children Under the Age of 13
The Company may collect and store persistent identifiers such as cookies or IP
addresses
from Children without parental consent for the purpose of supporting the internal
operation
of the Service.
We may collect and store other personal information about children if this
information
is
submitted by a child with prior parent consent or by the parent or guardian of the
child.
The Company may collect and store the following types of personal information about
a
child
when submitted by a child with prior parental consent or by the parent or guardian
of
the
child:
• First and/or last name
•
Date of birth
•
Gender
•
Grade level
•
Email address
•
Telephone number
•
Parent"s or guardian"s name
•
Parent"s or guardian"s email address
For further details on the information We might collect, You can refer to the "Types
of
Data
Collected" section of this Privacy Policy. We follow our standard Privacy Policy for
the
disclosure of personal information collected from and about children.
Parental Access
A parent who has already given the Company permission to collect and use his child
personal
information can, at any time:
•
Review, correct or delete the child"s personal information
•
Discontinue further collection or use of the child"s personal information
To make such a request, You can write to Us using the
contact
information provided in this
Privacy Policy.
Your California Privacy Rights (California"s Shine the Light law)
Under California Civil Code Section 1798 (California"s Shine the Light law),
California
residents with an established business relationship with us can request information
once
a
year about sharing their Personal Data with third parties for the third parties"
direct
marketing purposes.
If you"d like to request more information under the California Shine the Light law,
and
if
you are a California resident, You can contact Us using the contact information
provided
below.
California Privacy Rights for Minor Users (California Business and Professions Code
Section
22581)
California Business and Professions Code section 22581 allow California residents
under
the
age of 18 who are registered users of online sites, services or applications to
request
and
obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, You can
contact
Us
using the contact information provided below, and include the email address
associated
with
Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of
content
or information posted online and that the law may not permit or require removal in
certain
circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You
click on
a third party link, You will be directed to that third party"s site. We strongly
advise
You
to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy
policies
or
practices of any third party sites or services.
Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify You of any
changes by
posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to
the
change
becoming effective and update the "Last updated" date at the top of this Privacy
Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes
to
this
Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
By email: info@torontomandarinschool.com
By phone number: 416.304.2060