PRIVACY POLICY

Last Updated: January 29, 2020

CQB Education Inc. ("CQB", "we", "us" or "our") operates the CanadaQBank web-based applications and mobile device applications (the "App(s)"), as well as the website www.CanadaQBank.com (the "Website"), collectively, the "Service(s)".

CQB respects the privacy of its Users ("you" or "your") and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy describes the information we collect through our Services, how that information may be used, with whom it may be shared, and how it is protected.

This Privacy Policy is incorporated by reference in the Terms of Use (the "Agreement"). Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in the Agreement.

Please note that your use of the Services constitutes your agreement to follow and be bound by the terms of the Agreement and the Privacy Policy. If you object to anything in the Agreement or this Privacy Policy or if you do not want to agree to the Terms of Use or this Privacy Policy, do not use the Services.

1. Consent

By using, viewing or accessing the Services, including your use of the Website or Apps, you expressly consent and agree to this Privacy Policy and the collection, use and disclosure of information in accordance with this Privacy Policy.

Further, whenever you provide information to CQB or contact CQB through other means, you consent to the collection, use and disclosure of that information in accordance with the provisions of this Privacy Policy.

The Services are intended for and directed to Users over the age of majority. If someone under the age of majority is using, viewing or accessing the Services without the consent of their legal guardian, please contact us at [email protected].

Children Under the Age of 16: Our Services are not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on these Services (including the Website and the Apps) or on or through any of its/their features. If we learn that we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

2. Changes to the Privacy Policy

This Privacy Policy is subject to change and may be updated by CQB, at its sole discretion, from time to time. We will notify you of any changes by posting the revised policy or new policy on the Services.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy will be effective immediately upon posting the revised or new Privacy Policy to the Website or App. Any use of the Services after posting will constitute as acceptance of such new or revised Privacy Policy, and means you accept and agree to the changes.

Should we make any significant changes to the way we collect, use, share, and protect your Personal Information, we will let you know by posting notices on our Services and by sending you an email explaining the change. The date the Privacy Policy was last revised is identified 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.

3. Information Collection and Use

We collect different types of data, described below to provide and improve our Services to you.

i. Personal Information

While using our Services, we may ask you to provide us with certain personally identifiable information ("Personal Information"). Personally identifiable information is information that can be used on its own, or with other information to identify, contact or locate an individual. It does not include non-personal information like business information or generic information common to many individuals.

CQB collects Personal Information only if you voluntarily choose to share such information with CQB. In order to utilize the Services, however, we may require that you furnish Personal Information, such as when registering for a subscription to the Services. When you do so, you authorize us to collect, access, manage and retain information that may include, but is not limited to:

  • First name
  • Last name
  • Email address

ii. Other Data

We also collect, access, manage and retain data, other than Personal Information. These other types of data, described below, do not permit direct association with any specific individual.

Service-Related Data

We may collect and retain information related to your use of and access to the Services ("Service-Related Data"). For example, the following types of data may be collected:

  • test responses;
  • test scores;
  • study notes and questions;
  • Subscription details;
  • purchase history; and
  • frequency of your use of various features of the Services.

This data is collected to provide full functionality of the Services, such as providing analytics related to Users’ learning progress and test performance.

Device Data

When you use, view and access the Services, we may collect, using electronic means, device related information. This information may include the IP address, Internet browser, operating system, screen resolution, location or language settings of your computer or device used to view and access the Services ("Device Information").

Device Information is aggregated and used to measure and improve the effectiveness of our Services; accordingly, we may also share this aggregated data with advertisers and business partners. We do not combine Device Information with Personal Information we collect.

Cookies

We also collect anonymous information from Users of our Services and visitors to our Website through the use of cookies.

Cookies are small text files sent by us to your computer, and from your computer or mobile device to us each time you visit the Website. If you access the Services through an Internet browser, you can manage your cookie settings to accept or reject cookies, or simply notify you each time a cookie is set by a website you visit.

We do not use cookies to collect Personal Information, only to carry out site analytics and customization of the Services. This may include saving your login credentials and keeping track of a User's current session, if you give us permission to do so. We may also use cookies to provide customized web pages and advertisements. Cookie information is aggregated and used to improve the effectiveness of our Services, which may also include sharing this aggregated data with advertisers and business partners.

Payment Data

We do not collect any payment data. Payment details are collected and processed by a third-party payment processor.

We will do all that we reasonably can to ensure that the payment information which you provide when paying for the Subscription is secure. In the absence of negligence on our part, we will not be liable for any loss that you may suffer if a third-party gains unauthorized access to any information that you have provided in associated with registering a Subscription.

4. Use of Data

CQB may collect, access, manage and retain data and Personal Information for purposes, such as to:

  • provide and maintain our Services;
  • notify you about changes to our Services;
  • allow you to participate in interactive features of our Services;
  • inform you about our products and services;
  • provide customer support and respond to your inquiries;
  • administer a sweepstake, contest, or similar promotion, when you provide your consent to be entered into those programs;
  • perform analyses or gather valuable information so that we can improve our Services;
  • monitor the usage of our Services;
  • detect, prevent and address technical issues; and
  • maintain data security and user privacy.

5. Disclosure of Data

We reserve the right to use and disclose Personal Information to:

  • comply with applicable laws and regulations;
  • comply with governmental requests;
  • Protect against legal liability;
  • Prevent or investigate possible wrongdoing in connection with the Service;
  • Protect the personal safety of Users or the public; and
  • protect the rights and property of CQB and its Users, sponsors, providers, or licensors.

If CQB is legally compelled to disclose your Personal Information, it will only disclose the minimum amount necessary to meet our legal obligation.

6. Third-Party Links and Service Providers

The Services may contain advertisements, hyperlinks, references to third party websites or any of the preceding ("Third Party Materials"). CQB has no control over Third Party Materials and, accordingly, we have no responsibility or liability for the manner in which these organizations operate such links or referenced websites, or collect, use, disclose or secure and otherwise treat your Personal Information. Further, Third Party Materials may be governed by terms and conditions of those third-parties.

We may employ third-party companies and individuals to facilitate our Services ("Service Providers"), such as to process payment of a Subscription. We may transfer or otherwise make available Personal Information to our Service Providers who process it on our behalf for purposes related to providing the Services.

CQB expressly disclaims any liability derived from providing Personal Information to its Service Providers. Further, Users hereby agree to hold CQB harmless from any liability that may result from sharing Personal Information with third-party websites contained within the Services.

7. Security of Data

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All Personal Information you provide to us is stored on our secure servers behind firewalls. Thus, data will be stored on servers observing standard security protocols. However, the Internet is an open system and we cannot guarantee that unauthorized third parties will not be able to defeat those measures or use your Personal Information for improper purposes.

The safety and security of your Personal 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. You are responsible for keeping your account credentials and payment information confidential.

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. CQB is not responsible for circumvention of any privacy settings or security measures contained on the Services.

8. Transfer of Personal Information Internationally

i. Transfer of Personal Information Outside of Canada

For our Users in Canada, in some cases, Personal Information that we manage may be disclosed, processed and stored outside of Canada; therefore, it may be available to government authorities under lawful orders and law applicable there.

In particular, although this may change over time, our electronic business records are maintained through Google Cloud on a secure server located in Monks Corner, South Carolina, United States of America. Any electronic records generated during the course of business transactions with us will be maintained on that server.

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and Canadian law.

ii. Transfer of Personal Information Outside of USA

For our Users in the USA, in some cases, Personal Information that we manage may be disclosed, processed and stored outside of the USA; therefore, it may be available to government authorities under lawful orders and law applicable there.

In particular, although this may change over time, our electronic business records are maintained through Google Cloud on a secure server located in Monks Corner, South Carolina, United States of America. Any electronic records generated during the course of business transactions with us will be maintained on that server.

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and USA law.

9. Business Affiliates

CQB reserves the right to transfer, sell or distribute all information collected through the Services to an affiliate, subsidiary, or third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or stock.

We will use our best efforts to ensure that the new entity follows this Privacy Policy with respect to your Personal Information and to the extent required by applicable law.

10. Updating and Deleting your Data

All Service-Related Data, such as test scores, is deleted four (4) months after the expiration of your Subscription.

You will, however, be able to update your Personal Information on file by emailing CQB using the contact information provided below.

11. Contact Information

If you have questions or concerns regarding your Personal Information and this Privacy Policy, or to update, correct or delete your Personal Information, please contact [email protected].

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