Privacy Policy Statement

Last Revision: June 20, 2018

C5 Group Inc. (The Canadian Institute/American Conference Institute/C5 Communications) (“C5”, “we”, “us” or “our”, as appropriate) is committed to protecting the privacy and confidentiality of the personal information entrusted to it by the users of its products and services, prior and prospective customers, business partners and service providers and any other individual (collectively “Users” and individually a “User”, or “you” or “your”, as appropriate).

This Privacy Policy governs C5’s collection, use, retention and disclosure of the personal information of Users in any form, whether written or electronic, and explains how C5 collects, uses, discloses, retains and protects such Personal Information (as defined below).

C5 reserves the right to update its Privacy Policy at any time, and such modifications shall be effective immediately, unless otherwise stated. We recommend that you read this Privacy Policy carefully, and regularly check to see whether it has been modified. You are deemed to have accepted any modifications made to this Privacy Policy if you continue to provide Personal Information to us after publication of such modifications.

Acceptance of this Privacy Policy
By submitting your Personal Information to C5, you acknowledge and agree to the terms and conditions of this Privacy Policy. If you do not agree to this Privacy Policy, please do not submit your Personal Information to us.

What is Personal Information?
For the purposes of this Privacy Policy, the term “Personal Information” means any information about an identifiable individual, such as name, birth date, address and other information pertaining to such individual’s identity, as well as financial information, which may be presented in any form.

The type of Personal Information collected by C5 depends on a number of factors and context. C5 collects only the Personal Information it deems necessary for conducting its business and for the purposes identified in this Privacy Policy.

Children
If you are under the age of majority in the jurisdiction you reside, please obtain your parent or guardian’s permission before you send any Personal Information to us, or anyone else. We encourage parents and guardians to monitor their children’s online usage and to be aware of the activities in which they are participating.

What Personal Information we collect and how we collect them
C5 may collect Personal Information from you when (i) you sign up for one of our newsletters; (ii) request information on, purchase or subscribe to any product or service from C5 (including our publications); (iii) register on any online forum available or attend a paid event on our website; (iv) you participate in certain promotional activities, complete surveys, and correspond with us, or (v) you provide freelance or other services to us. We may also collect your Personal Information from other offline sources, such as when you call us by phone, visit us at an event, or participate in a survey.

The Personal Information we collect includes your name, mailing address, phone number, e-mail address and other information as required for you to access and use our website and to provide you with our products and services. This includes your payment information.

We may also collect additional Personal Information from you when you act as freelancers, as other service providers and/or as advertisers for C5, such as financial information (for example, banking details and credit history) to assess credit risk, sales data to prepare royalty reports and other relevant information to help us evaluate the quality of your services and pay you for the services provided.

In addition to Personal information, we may automatically collect information when you use our website. This may include the browser you used to come to our website, the Uniform Resource Locator (“URL”) of the web site that you just visited before visiting our website, your access times, language, your usage and activity on our website, your location, any search terms you entered, which URL you go to next, and your Internet Protocol (“IP”) address. We may use third-party analytics, cookies and other online tracking technologies to help us collect information of Users who visit our website.

We may also collect your demographic information, your purchase history and/or the list of promotions offered to you, in order to gain a better understanding of your interests so that we may develop better products and services, and to determine your eligibility for other products and services.

Finally, we may occasionally ask Users to complete market research surveys. If you choose to participate in these surveys and provide your personal information for that purpose, your information will be aggregated as part of the survey results and shared with our advertisers, sponsors and affiliates in a manner that does not identify you.

How we use your Personal Information
We may use the Personal Information we collect for the following purposes:

  1. Provision of C5 products and services: to fulfill your request for information and your order of any products or services, to respond to any of your inquiries on the same and to notify you with any changes, enhancements or other notices related to products and services of your interests;
  2. Improvement of User experience: to personalize your experience and to allow us to deliver the type of content and product offers that interest you, and to help us develop and market our brand, products, services, promotions and advertising;
  3. Newsletters and other Marketing activities: we may send you (via e-mail or Postal Service) newsletters, promotional information and other information using your Personal Information. We may also use your Personal Information to send you offers or information from us, our affiliates and from selected sponsors or advertisers (“Marketing Offers”). These mailings, including Marketing Offers, will only be sent to you if you have agreed to receive them and have not opted out at the time of sending. You may choose to stop receiving our newsletter or Marketing Offers, at any time, by following the unsubscribe instructions included in these emails or by following the opt-out procedure below;
  4. Contact information: if you contact us, we may keep a record of your correspondence or comments, including any information therein. We use this information to help us provide you with better services, and to follow-up on any inquiries or claims you made relating to our services;
  5. Management of your account: we also use your Personal Information to administer and process our website and services, such as registering your account on our website, authenticating you when you log into your account, and providing you with reward points or apply credit, as applicable in the circumstances;
  6. Generating statistics: to measure our website activities and detect and prevent security threats; and
  7. Compliance with our legal obligations: to meet all relevant and applicable regulatory, legal, insurance, audit, security and processing requirements.

Other than as permitted or required by applicable laws, if we wish to collect, use or disclose your Personal Information for purposes that are not contemplated in this Privacy Policy, we will identify those purposes at the time of collection. You will be given a reasonable opportunity to opt-out of any such additional purposes.

Disclosure to third parties
C5 may disclose your personal information to third parties as follows:

  1. To our affiliates for internal audit, management, billing or other administrative purposes;
  2. To C5 affiliates, selected sponsors and advertisers in order for them to send you Marketing Offers. If you do not wish to receive Marketing Offers, you may opt-out at any time by following the opt-out procedure provided herein;
  3. To our third party service providers in order to fulfill your order of our product and services or to perform specific services on our behalf (such as credit card processing, credit card information updates, prize fulfillment of our contests, collection of overdue accounts, management of customer service requests, and product delivery);
  4. To parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of C5 business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties; and
  5. To our legal advisors or appropriate governmental authorities, if you have violated our terms of service or conditions of purchase, or if we need to comply with applicable laws and lawful governmental requests, and for legal reasons.

Your Personal Information may be processed and stored outside of the province in which you reside and/or outside of Canada by us, an affiliate or a third party service provider for the purposes set out in this Privacy Policy and, under the laws of these other jurisdictions, in certain circumstances, foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your Personal Information.

Opt-Out
From time to time and as agreed by you, we make will make your contact information available to other reputable organizations whose products or services you might find interesting. Additionally, if you provide us with your telephone number, we may contact you by telephone with information regarding new products and services, or upcoming events.

If you do not wish for us to do so, or to be contacted by us regarding our own promotions and upcoming events, please let us know by sending us a notification on-line, by e-mail, by calling us or by writing to us at the contact information provided below.

If you choose to opt-out of any use of your Personal Information in accordance with these opt-out provisions, we will keep your contact information on a list so that your request can be honoured.

Please note that the contact details provided to us for the purpose of forwarding conference information through our “Send to a Friend” feature is restricted. This means that no unsolicited emails will be sent to contacts whose information is provided by way of this function, nor will their contact information be disclosed or sold to third parties.

Please allow for up to 10 days to be removed from our email list and 4 weeks to fully process your removal from our hard copy mail list.

Protection of your Personal Information
C5 employs best efforts to maintain technical, contractual, administrative and physical security measures to protect your Personal Information in a manner that is reasonable and appropriate to the nature of the Personal Information you provide to us. For example, when you provide credit card information to us, we work to help protect the security of your credit card information by using industry standard secure sockets layer (SSL) encryption technology.

However, please be aware that email is not a secure medium, and any Personal Information you send to us by email could be intercepted. If your communication is very sensitive, or includes information such as your credit card number, you should not send it electronically unless the email is encrypted or your browser indicates that the access to our website is secure.

Materials posted to online forums such as bulletin boards or comment sites are public, not secure and may be viewed by anyone. Any Personal Information you post may be collected and used by anyone and may result in unsolicited messages from other internet users.

C5 is not responsible for Personal Information you choose to post or submit in any online forum on our website.

Cookies
If you use our website, we may assign an internet cookie. An internet cookie is a small text file that a website stores on your internet browser and that can collect and store information. We use cookies to better understand how you use our website, to make sure our ads and dynamic content are served correctly and to improve the performance of our website. For example, a cookie may recall a set of preferences you have set for our website and record items that you have registered. Storing cookies on your web browser allows us to present you with web pages and other content that are attuned with your preferences. These activities are invisible to you, and are generally intended to improve your internet surfing convenience. Unless you have set your preferences so that you will be alerted when a cookie is being stored on your computer, you will not know about it.

We may place advertising or other links on our website that originate from outside advertisers. We do not control cookies on these sites, nor are we responsible for any marketing or other use of your information by these advertisers.

Third party websites
Our website, including products or services available therein, may contain hyperlinks or other “computer” links to website from third parties (“Third Party websites”) that can cause leaving the website currently browsed by the User. C5 provides these links only for convenience, and the inclusion of any link does not imply endorsement by C5 of the content of the website it is linked to. Accordingly, any Personal Information that is transmitted by use of Third Party Websites is subject to the privacy policy of the relevant Third Party Websites. It is the responsibility of the Users to consult these policies in order to ensure that their Personal Information is being protected.

Furthermore, C5 ASSUMES NO RESPONSIBILITY FOR ANY MATERIAL OUTSIDE OF OUR WEBSITE, INCLUDING ANY WEBSITES WHICH MAY BE ACCESSED THROUGH A LINK ON OUR WEBSITE. C5 specifically disclaims responsibility for any inadvertent viewing by anyone under the age of 18 of any material intended for adults on a website accessed through use of a linked website.

Retention of your personal information
We keep your Personal Information for such period as is reasonably necessary to meet the purposes for which it was collected or to comply with any legal requirements, including statutory retention periods. When your Personal Information is no longer required for a specific purpose or legal requirement, it will be erased from our records or made anonymous.

How to access and correct your personal information, and address concerns regarding your privacy
If your Personal Information changes, or if you no longer desire us to use your Personal Information, you may request us to correct, update, amend, delete/remove your Personal Information. Please contact us at the contact information provided below in order to do so.

We may require that you provide us with valid proof of identity before providing access to such information.

European Economic Area (EEA) Notice
If you are located in a country in the European Union (EU) and utilize our Website tools which are offered to EU residents, or if we collect, track, use or process in some other way your personal information collected from you or through your use of our Website, or we transfer that personal information, we will do so in accordance with this Privacy Policy, the applicable Website Terms of Use and in compliance with applicable requirements of the General Data Protection Regulation (EU 2016/679) (GDPR).

Transfers of Personal Information
C5 is a data controller and is responsible for your personal information, which the C5 processes and stores in Canada. The European Commission has decided that Canada ensures an adequate level of protection of individuals’ personal information. C5 may use the following safeguards when transferring your personal information to a country, other than Canada, that is not within the EEA:

  1. Only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of protection for personal information;
  2. Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in the EU.

Opt-in
If you are an EU resident, we may only collect your data using cookies and similar devices, and then track and use your personal information where you have first consented to that. We will not automatically collect personal information from you unless you have consented to us doing so. If you consent to our use of cookies and similar devices, you may at a later date disable them.

Your Legal Rights
Under certain circumstances, as an EU resident, you may have rights in relation to your personal information, including the right to:

  • Request access to your personal information.
    This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

  • Request correction of your personal information.
    This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

  • Request erasure of your personal information.
    This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal information.
    You may exercise this right in the event that we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

  • Request restriction of processing your personal information.
    This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.

  • Request transfer of your personal information.
    Upon your request, we will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Right to withdraw (revoke) consent.
    You may exercise this right where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact our Privacy Officer. Please also note that the following will apply:

No Fee Usually Required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we my charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You
We may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you have any questions, concerns or claims about this Privacy Policy and our privacy practices, please contact us at:

RE: PRIVACY POLICY
C5 Group Inc.
1329 Bay St
Toronto, ON M5R 2C4
Email: [email protected]
Telephone: 1-877-927-7936
Facsimile: 1-877-927-1563 or 416-927-1563