Privacy Policy

Free the Goldfish Coaching Inc. – Personal Information Protection Policy

At Free the Goldfish Coaching Inc. (the “Company”), we are committed to providing our Customers with practical personal development tools, products and services to help them achieve their personal visions.  As providing these resources may involve the collection, use and disclosure of Personal Information about our Customers, protecting their Personal Information is one of our highest priorities.

This Personal Information Protection Policy (this “Policy”) outlines the principles and practices we will follow in protecting Customers’ Personal Information and allowing our Customers to request access to, and correction of, their Personal Information.  This Policy was developed in compliance with the Personal Information Protection Act (British Columbia) (“PIPA”).  PIPA sets out rules for how private sector organizations in British Columbia can collect, use and disclose Personal Information.

Scope of this Policy

This Policy applies to the Company and any service providers collecting, using or disclosing personal information on behalf of the Company.

Definitions

“Personal Information” means information about an identifiable individual, including an individual’s name, home address, social insurance number, sex, income, or family status.  Personal Information does not include Contact Information (defined below).

“Contact Information” means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact Information is not covered by this Policy or PIPA.

“Privacy Officer” means the individual designated responsible for ensuring that the Company complies with this Policy and PIPA.

“Customer” means any individual who provides personal and/or contact information to the Company through its programs or through our website.

Policy 1 – Collecting Personal Information

  1. Unless the purposes for collecting Personal Information are obvious and the Customer voluntarily provides his or her Personal Information for those purposes, we will communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection.
  2. We will only collect Personal Information that is necessary to fulfill the following purposes:To identify Customer preferences;
    • To identify Customer preferences;
    • To understand the personal development needs of our Customers;
    • To deliver requested tools, products and services;
    • To send out Company information;
    • To survey our Customers;
    • To ensure a high standard of service to our Customers;
    • To improve our products, services and website; and
    • To meet regulatory or other legal requirements.
  3. The following are examples of the types of Personal Information we typically collect from Customers: first and last name, email address and province/state of residence.
  4. We may use cookies and other technologies to collect information about Customers when they visit our website.  A “cookie” is a file that may be placed on a Customer’s hard drive without the Customer’s knowledge.  The cookies we use do not allow us to identify individuals. Cookies may be removed by you through your internet browser; see the product documentation for more information.  The information we collect about Customers when they visit our website is used to compile statistical information on traffic patterns and to assess site efficiency.  We do not use this information to identify individual Customers.  The following are examples of information we may collect with these technologies:
    • The Customer’s browser type and operating system;
    • Web pages the Customer views;
    • Links the Customer clicks;
    • The Customer’s IP address;
    • Sites the Customer visited before coming to our site;
    • Emails from the Company that the Customer opens and/or forwards; and
    • Offers or links the Customer connects to via emails from the Company.

Policy 2 – Consent

  1. We will obtain Customer consent to collect, use or disclose Personal Information (except where, as noted below, we are authorized to do so without consent).
  2. Consent can be provided in writing or electronically or it can be implied where the purpose for collecting, using or disclosing the Personal Information would be considered obvious and the Customer voluntarily provides Personal Information for that purpose.
  3. Consent may also be implied where a Customer is given notice and a reasonable opportunity to opt-out of his or her Personal Information being used for mail-outs, the marketing of new services or products, or surveys and the Customer does not opt-out.
  4. Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), Customers can withhold or withdraw their consent for the Company to use their Personal Information in certain ways.  A Customer’s decision to withhold or withdraw their consent to certain uses of Personal Information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the Customer in making the decision.
  5. We may collect, use or disclose Personal Information without the Customer’s knowledge or consent in certain limited circumstances permitted under PIPA, which circumstances may include:
    • When the collection, use or disclosure of Personal Information is permitted or required by law;
    • To protect ourselves from fraud or suspected fraud; and
    • To investigate an anticipated breach of an agreement or a contravention of law.

Policy 3 – Using and Disclosing Personal Information

  1. We will only use or disclose Customers’ Personal Information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
    • To conduct Customer surveys in order to enhance the provision of our tools, products or services;
    • To contact our Customers directly about information, products and/or services that may be of interest;
    • To understand how Customers arrived at our site; and
    • To further improve our website and/or information, product and/or service offerings.
  2. To conduct Customer surveys in order to enhance the provision of our tools, products or services;
  3. To contact our Customers directly about information, products and/or services that may be of interest;
  4. To understand how Customers arrived at our site; and
  5. To further improve our website and/or information, product and/or service offerings.
  6. We may share a Customer’s Personal Information with our third-party service suppliers, including those who work on behalf of the Company, to deliver the information, products and/or services the Customer has requested from the Company.
  7. We may also share Customer information when required by law or if we are otherwise authorized by PIPA.
  8. We will not sell Customer lists or Personal Information to other parties.

Policy 4 – Retaining Personal Information

  1. If we use a Customer’s Personal Information to make a decision that directly affects the Customer, we will retain that Personal Information for at least one year so that the Customer has a reasonable opportunity to request access to it.
  2. Subject to policy 4.1, we will retain a Customer’s Personal Information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

  1. We will make reasonable efforts to ensure that a Customer’s Personal Information is accurate and complete where it may be used to make a decision about the Customer or disclosed to another organization.
  2. Customers may request correction to their Personal Information in order to ensure its accuracy and completeness.  A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought.  The request must be sent in writing or electronically to the Privacy Officer, per the contact information at the end of this Policy.
  3. If the Personal Information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year.  If the correction is not made, we will note the Customer’s correction request in the file.

Policy 6 – Securing Personal Information

  1. We are committed to ensuring the security of our Customers’ Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
  2. We have implemented security measures to ensure Customer Personal Information is appropriately protected from unauthorized access, loss or theft, modification and other threats.  We use security safeguards appropriate to the level of sensitivity of the Personal Information including encryption and password protection.  We may use a third-party service providers (for example, web hosting providers and/or a data management providers) to store Customer Personal Information.  Our third party service providers may be located in the United States and, accordingly, Customer Personal Information may be stored in the United States.  If we use third-party service providers, we will ensure they have adequate security measures in place to safeguard Customer Personal Information.
  3. We will use appropriate security measures when destroying a Customer’s Personal Information such as deleting electronically stored information.
  4. We will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.

Policy 7 – Providing Customers Access to Personal Information

  1. Customers have a right to access their Personal Information, subject to limited exceptions.
  2. A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought.  The request must be sent in writing to the Privacy Officer, in accordance with the contact information at the end of this Policy.
  3. Upon request, we will also tell Customers how we use their Personal Information and to whom it has been disclosed, if applicable.
  4. We will make the requested information available within 30 business days or provide written notice where additional time is required to fulfill the request.
  5. A minimal fee may be charged for providing access to Personal Information.  Where a fee may apply, we will inform the Customer of the cost and request further direction from the Customer on whether or not we should proceed with the request.
  6. If a request is refused in full or in part, we will notify the Customer in writing, providing the reasons for refusal and the recourse available to the Customer.

Policy 8 – Questions and Complaints:  The Role of the Privacy Officer

  1. The Privacy Officer is responsible for ensuring the Company’s compliance with this Policy and the Personal Information Protection Act.
  2. Customers should direct any complaints, concerns or questions regarding the Company’s compliance in writing to the Privacy Officer.  If the Privacy Officer is unable to resolve the concern, the Customer may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for the Company’s Privacy Officer:

Privacy Officer

Free the Goldfish Coaching Inc.
154 – 991 Hornby Street
Vancouver, BC  V6Z1V3
Canada