Privacy – Penrose Academy

Privacy Policy

This privacy policy sets out how the Penrose Academy uses and protects any information that you give Penrose Academy when you use this website.

Penrose Academy is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

Penrose Academy may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from January 1, 2006.

What we collect

We may collect the following information in order to provide information or services to you when using our website information request forms, subscriptions to newsletters, or contacting our customer service representatives by phone. We only collect personally identifiable information that you submit voluntarily:

name and job title
contact information including email address and telephone
demographic information such as postcode, mailing addresses, preferences and interests
other information relevant to customer surveys and/or offers

What we do with the information we gather

Penrose Academy collects personal information only with the express consent of the user when they request information from our organization. This information is only used when communicating with users as per their indicated preferences and as needed for service-related communications. We may use the information you provide for:

Internal record keeping.
To improve our products and services.
To send promotional communication about special offers or other information which we think you may find interesting using the email address which you have provided.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.
We may use the information to customize the website according to your interests.

Opting Out

Penrose Academy provides users with the ability to opt out from communications from any of our newsletters. An opt out option will either appear at the bottom of a newsletter received by email, or users can reply directly to the emailed newsletter and request removal from that correspondence.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Enrollment Resources Privacy Policy

Last Updated February 8, 2021

Table of Contents

INTRODUCTION
INFORMATION WE COLLECT ABOUT YOU
HOW WE COLLECT INFORMATION ABOUT YOU
INFORMATION YOU PROVIDE US
INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES
THIRD PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
HOW WE USE YOUR INFORMATION
DISCLOSURE OF YOUR INFORMATION
TRANSFERRING YOUR PERSONAL INFORMATION
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
DATA SECURITY
DATA RETENTION
CHILDREN UNDER THE AGE OF 16
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
WITHDRAWING YOUR CONSENT
CHANGES TO OUR PRIVACY POLICY
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
RESIDENTS OF THE EUROPEAN ECONOMIC AREA
RESIDENTS OF CALIFORNIA
GOOGLE USER DATA
GOVERNING LAW
FOR MORE INFORMATION OR ASSISTANCE

INTRODUCTION

Enrollment Resources Inc. is a Canadian Company focused on connecting students with schools. We help schools with website and paid search management. We help students decide if a school is right for them. In doing so, we help our clients collect data from students. Read more below to find out how exactly we do this.

Enrollment Resources Inc. and our affiliates and subsidiaries ("Company" or "We") respect your privacy and are committed to protecting it by complying with this policy. We understand that as a data subject, your information is important to you.

This policy describes:

How we collect, use, disclose, and protect the personal information of our customers and website users ("you").
The types of information we may collect from you or that you may provide when you visit this website (our "Website"), or affiliate websites. This may include, but is not limited to: https://enrollmentresources.com/, and virtualadviser.com.
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 as set out in this policy.

Privacy laws in Canada, the United States, and the European Union may generally define "personal information" as any information about an identifiable individual, consumer, or household, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Note, data protection laws in several jurisdictions draw comparison between the "controllers" and "processors" of personal information. In general, Enrollment Resources performs the role of a processor on behalf of our clients who are the controllers.

This policy applies to information we collect, use, or disclose about you:

On this Website.
In email, text, phone and other electronic messages between you and this Website.
When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
Through any of our affiliate companies.
Including on any other Company or third-party website (including our affiliates and subsidiaries).

The Website 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.

This policy DOES NOT apply to information that:

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. To be clear, Enrollment Resources does not collect the same information as our clients. For information on our client's privacy policies, please review their privacy policy, and contact their Privacy Officer.

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 Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

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, and any other identifier we may use to contact you ("personal information"). We also collect any other information you choose to send us. Please do not provide us with your billing and account information, social insurance number, or health card number. Furthermore, do not provide us with any criminal, or offence history.
We provide an opportunity for any user to unsubscribe from our emails or opt-out of contact for marketing or data purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or by e-mailing to privacy@enrollmentresources.com.
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.
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 Website, and usage details.
Non-personal details about your Website 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, search terms and search engines, 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.
Analytics, such as Google Analytics.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

Direct interactions with you when you provide it to us, for example, by registering online, or use of any of our products or services.
User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties.
Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, domain, country and information collected through cookies, web beacons, and other tracking technologies.
Third parties or publicly available sources, for example, our business partners.
FullContact Person API. We use your email address to look up additional publicly available data including public profile picture, and social media profiles.
The use of unique phone numbers to record calls.

INFORMATION YOU PROVIDE US

The information we collect directly from you on or through our Website may include:

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, posting material, or 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.
Records and copies of your correspondence (including email addresses), if you contact us.
Details of transactions you carry out through our Website and of the fulfillment of your orders.
Your search queries on the Website.
Information you post to any "third party affiliates."

INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
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 the Digital Advertising Alliance of Canada Opt-Out Tool 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 technologies we use for this automatic data collection may include:

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.
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 the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

THIRD PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications on the Website, 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 Website.

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 and an opt-out tool created by the Network Advertising Initiative. 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.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To email you regarding your progress on our website.
To share your information with the education institution represented when you register.
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.
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.
To notify you about changes to our Website or any products or services we offer or provide though it.
To improve our Website, products or services, marketing, or customer relationships and experiences.
To allow you to participate in interactive features, social media, or similar features on our Website.
To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
In any other way we may describe when you provide the information.
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 check the relevant box located on the form on which we collect your data, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at privacy@enrollmentresources.com.

DISCLOSURE OF YOUR INFORMATION

We do not sell any of your information to third parties. However, we may disclose aggregated information about our users, and information that does not identify any individual.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To the controller of the website in which you input data.
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 Enrollment Resources Inc.'s assets.
To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others.
To third parties to market their products or services to you if you have consented to these disclosures.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Enrollment Resources Inc., our customers, or others.

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 and who are contractually obligated to keep personal information confidential.

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. You are welcome to contact us at privacy@enrollmentresources.com to obtain further information about Company policies regarding service providers outside of Canada.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
The information supplied to us may be collected, used, disclosed, stored, or processed in Canada, the United States of America, the United Kingdom, or the European Union.

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:

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.
Promotional Offers from the Company. If you 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 privacy@enrollmentresources.com.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by sending us an email stating your request to privacy@enrollmentresources.com.

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. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted using SSL technology. Our data is stored in Canada and the United States.

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 Website. Any transmission of personal information is at your own risk.

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. Generally, we retain your data for 5 years. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you.

CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to the Website. We do not knowingly collect personal information from children under 16. If you believe we might have any information from or about a child under 16, please contact us at privacy@enrollmentresources.com.

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 send us an email at privacy@enrollmentresources.com to request access to, correct, or delete any personal information that you have provided to us.

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 privacy@enrollmentresources.com. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. It may take up to 3 business days to fulfill your request.

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 through a notice on the Website home page. We include the date the privacy policy was last revised at the top of the page.

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
#216-611 Brookside Road
Victoria, British Columbia
Canada V9C 0C3
Phone: 1-250-391-9494

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.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA

In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European consumers and users, this Privacy Policy outlines the legal basis on which we process your Personal Information and provides other information required by the GDPR.

In addition to the common rights granted to all users, the GDPR provides the following additional rights to residents of the European Economic Area:

Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Information, as permitted by law.
Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances.
Right to data portability (Art. 20 GDPR): You have the right to receive the Personal Information that you have provided to us, in a structured, commonly used and machine-readable format.
Right to object (Art. 21 GDPR): You have the right to object to our processing of your Personal Information, as permitted by law.
Right to lodge a complaint before the Data Protection Authority (Art. 77 GDPR): You have the right to lodge a complaint with a competent data protection supervisory authority.

RESIDENTS OF CALIFORNIA

In order to comply with the requirements of the California Consumer Privacy Act (CCPA), this Privacy Policy further outlines the legal basis on which we collect and process your Personal Information.

We do not sell Personal Information and have not done so in the past 12 months.

Information We Collect

We have collected the following categories of personal information from consumers within the last twelve (12) months:

Categories	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, physical characteristics or description, address, telephone number, education, employment, employment history.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information.	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics or activity patterns.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per FERPA).	Education records directly related to a student maintained by an educational institution.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by:

Calling us at 1-250-391-9494
Emailing us at privacy@enrollmentresources.com

GOOGLE USER DATA

Our software may give you the option to login with your Google Account to enable additional functionality. Currently, we use Google User Data for displaying relevant Google Analytics data from your website to compare with our visitor data, and calculate conversion rates in a convenient dashboard.

GOVERNING LAW

Enrollment Resources Inc. controls and operates this Site in Canada. Our online privacy practices are governed by the laws of Canada and British Columbia, which may differ from privacy laws in your province, state or home country. By submitting your Personal Information to this Site or to an affiliate, you consent to the transfer of your Personal Information to any country and its use and disclosure in accordance with Canadian federal and British Columbian provincial law and with this Privacy Policy.

FOR MORE INFORMATION OR ASSISTANCE

If you have any questions regarding this Privacy Policy or the privacy practices of Enrollment Resources or its affiliates, or if you require assistance to withdraw your consent or wish to request that your Personal Information be deleted, please contact us:

Enrollment Resources
#216-611 Brookside Road
Victoria, British Columbia
Canada V9C 0C3
Attention: Chief Privacy Officer
Email: privacy@enrollmentresources.com