Privacy Policy

Privacy Policy – Virtual Classes

This Privacy Policy explains how we handle personal information when you register your child to attend one of our virtual classes (our “Services”). This Privacy Policy does not apply to our tutoring services, including how we handle students' personal information. Please click here to read our Privacy Policy for our tutoring services. Additionally, this Privacy Policy does not apply to our how we handle your personal information when you use our website, interact with us on social media or otherwise communicate with us by e-mail. Please click here to read our Privacy Policy for marketing activities.
If you have any questions, concerns or inquiries regarding the collection, use or disclosure of your or your child’s personal information that you provide, do not hesitate to reach out to us. You can e-mail us at privacy@paper.co, or reach us by mail at the following address:


Paper Education Company Inc.
279 Sherbrooke St West, Suite 410
Montreal, QC, H2X 1Y2
Canada

1. What is personal information?

We consider that “personal information” means any information that allows us to identify you directly or indirectly, including cookies and other electronic data. This Privacy Policy is for transparency purposes and some of the data that we identify in this Privacy Policy as personal information may not be protected as personal information under applicable laws.
A “cookie” is an information that a website puts on a computer’s hard disk so that a website or web application can remember something about individuals at a later time. In this Privacy Policy, when we refer to “cookies” we also include other technologies with similar purposes, such as pixels, tags and beacons. For more information on cookies, you can refer to websites such as http://www.cookiecentral.com/ and https://www.allaboutcookies.org/.

2. When is this Privacy Policy not applicable?


This Privacy Policy only applies to how we process the personal information of our users within our Services and does not apply to our marketing activities and website, which are not within the Services. We do not leverage user data for marketing purposes.
Our Services may contain links towards external services which are not part of the Services. For instance, an instructor may provide a student with a link to a website to learn more about a certain topic. These external services are not covered by this Privacy Policy.


3. What personal information do we collect and why?


We collect the following types of personal information:
• Electronic Data
Electronic data is collected automatically when you browse the Internet, so whenever you register your child for classes on our website, we also collect electronic data about you. Electronic data includes information such as your device's Internet Protocol address (e.g., IP address), browser type, browser version, and which pages on our website you visit.
• Identification Data
If you register your child for virtual classes, we collect the following identification I information:
• Guardian’s name
• Guardian’s Email
• Student’s name
• Student’s age
• Student’s school
• Support Data

When users are using the Services, they may have some questions on how to use the Services or face some bugs or errors. To assist users, we have a support desk available to respond to support requests. We collect any information shared with us through support services.


4. Do you use any cookies as part of the Services?


The cookies we use can be separated in the categories below. Some of them are installed for your session, others are installed for several months on your computer.

Type of cookie Description

 

Categories of recipients

Explanations

IT Service Providers

We use service providers to provide and host our Services online. For instance, our Services are hosted on Google Cloud Platform.   IT Service Providers may also be used for security purposes, such as for log monitoring.

Analytics and Performance Providers

We use third-party service providers to monitor and analyze the use of our Services. For instance, we use Google Analytics. Google Analytics is a web analytics service offered by Google that provides us with aggregated data on how our Services are used by visitors. Google may use the collected data to contextualize and personalize ads of its own advertising network. You can find Google’s Privacy Policy here.

Communication Partners

We use third parties to provide you with e-mail notification. For instance, we use Mailchimp and Mandrill, an add-on to Mailchimp, to provide teachers and students with notifications. We have not enabled any marketing functions within MailChimp’s additional add-ons.

Video Platform Providers

All virtual classes will be offered via the Zoom video platform. You can find Zoom’s Privacy Policy here.

CRM Platform Providers

We use CRM platforms to manage our customer database. For instance, we use Hubspot CRM platform.  

Law enforcement and other authorities

We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected (i) in response to a law enforcement or public agency’s request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability. 

 

5. Do we conduct interest-based advertising?


We conduct interest-based advertising, also referred to as targeted advertising or behavioral advertising. Please click here to read our Privacy Policy for marketing activities.


6. How can you manage your cookies?


Browsers have tools that allow you to control cookies; you can block them, ensure that you are notified when you are subject to cookies and control the cookies already stored on your device. However, if you block all of the cookies, you may not be able to access all the functionalities of the Services.


You can also use WebChoices which is a browser-based tool for opting out of interest-based advertising. AdChoices offers solutions and information to manage your preferences regarding cookies, as well as plug-ins to retain opt-out cookie preferences, even if you delete your cookies.


You can manage your cookie preferences through your browser using the instructions provided below by clicking on the browser that you are using. However, by blocking essential and functional cookies, parts of the Services may not be available.
• Google Chrome
• Firefox
• Safari
• Internet Explorer
• Opera

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 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.


7. Where is your personal information stored?


Our website is hosted in the United States. Some of our service providers may be located elsewhere, and we are headquartered in Canada.


8. How is your personal information protected?


Your personal data is hosted in a cloud platform that has many certifications based on the safeguards that they implement to protect your data, such as ISO 27017, ISO 27018 and ISO 27001. You can review Google Cloud Platform’s safeguards on Google’s Trust & Security Center available here. Within Paper, we ensure that your personal data is only accessed on a need-to-know basis by our employees.


9. How is personal information shared?


Virtual camps are conducted using video conference services such as Zoom. You should be aware that any information your child provides during the video conference will be made publicly available to others participating in virtual camp or other persons who may be in the same household as other camp participants. This includes any information provided using the chat feature. The child’s first name will also be displayed to other participating campers. Parents should carefully supervise their children when they participate in these online activities. Please note that video participation is voluntary. The video feature does not have to be enabled to participate in the Services.


We share your personal information to the categories of recipients identified in this table and for the reasons identified below.
Categories of recipients Explanations


IT Service Providers We use service providers to provide and host our Services online. For instance, our Services are hosted on Google Cloud Platform. IT Service Providers may also be used for security purposes, such as for log monitoring.


Analytics and Performance Providers We use third-party service providers to monitor and analyze the use of our Services. For instance, we use Google Analytics. Google Analytics is a web analytics service offered by Google that provides us with aggregated data on how our Services are used by visitors. Google may use the collected data to contextualize and personalize ads of its own advertising network. You can find Google’s Privacy Policy here.


Communication Partners We use third parties to provide you with e-mail notifications. For instance, we use Mailchimp and Mandrill, an add-on to Mailchimp, to provide teachers and students with notifications. We have not enabled any marketing functions within MailChimp’s additional add-ons.


Video Platform Providers All virtual classes will be offered via the Zoom video platform. You can find Zoom’s Privacy Policy here.
CRM Platform Providers We use CRM platforms to manage our customer database. For instance, we use Hubspot CRM platform.
Law enforcement and other authorities We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected (i) in response to a law enforcement or public agency’s request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

If we go through a restructuration, a merger and acquisition or a sale of parts of all of our assets, personal information may also be shared for this purpose. If we are acquired, your personal information may be sold with our assets.


9. How long do we retain your personal information?


We retain personal information for as long as necessary to provide you with the Services, to perform our marketing campaigns effectively or as required by applicable laws, whichever is longer.


10. What rights do you have over your personal information?


Depending on your location, different rights may be applicable.


Parental Rights and Controls


We will not require a child to disclose any personal information to participate in the services and any information voluntarily disclosed during a virtual class is not collected, recorded or maintained by us. If you are a parent or guardian, you can review or have deleted your child’s personal information that you provided when registering them for the Services. To exercise these rights, please contact us using the mailing address below.


Your Canadian Privacy Rights


Applicable laws generally contain a minimum of two rights: (1) the right to access personal information and (2) the right to modify personal information, in certain circumstances.


If you want to exercise one of these rights and the situation allows for such exercise, we will help you without additional charges. However, if you request a transcription, reproduction or transmission of your personal data, we may have to charge a reasonable fee to process your request, subject to applicable laws. In this case, we will contact you about these charges before addressing your request.


For security reasons and to avoid any fraudulent request, we may be required to ask that you provide a proof of identity with your request. After the request has been handled, we will securely delete such personal data.


If your request is denied, we will notify you in writing, provide you with detailed motives and information on how to contest our decision. We will keep the relevant personal data until you have exhausted your options. In any event, we will respond to your request within thirty (30) days.


If you are located in Canada, note that the Office of the Privacy Commissioner of Canada drafted this FAQ to help you access your personal information when it is held by a business. You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:


Mailing address
Office of the Privacy Commissioner
30 Victoria Street
Gatineau, Québec
K1A 1H3


You can also use this online form.


If you have any issue with how we collect, use or disclose your personal data, or how we responded to your request, please let us know. We will do our best to improve our processes to make certain that it does not happen again. We will also provide you with additional information about our practices if you would like us to do so.


If you are still not satisfied, you can lodge a complaint to the Office of the Privacy Commissioner of Canada using this online form, or to your local privacy regulators.


To exercise your right, you can simply reach out to us at privacy@paper.co. You can also reach out to us by mail at the following address:


Paper Education Company Inc.
279 Sherbrooke St West, Suite 410
Montreal, QC, H2X 1Y2
Canada

If you are located outside Canada, please contact your local privacy authority.


Your California Privacy Rights


California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. We do not share personal information for these purposes.

Your ‘Do Not Track’ Browser Setting.

Our websites do not accept or process such Do Not Track signals or similar mechanisms. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

11. Can this Privacy Policy be modified?


Yes, it is our practice to keep this Privacy Policy updated to reflect our current practices. You should visit this page from time to time. You can see the latest date of the modification at the top of the Privacy Policy.

 

 

Have questions?

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