Privacy Policy - Website and Marketing

Latest update: December 2020

This Privacy Policy explains how handle your personal information when you use our website, interact with us on social media or otherwise communicate with us by e-mail. This Privacy Policy also covers our marketing activities (together, our “Services”). This Privacy Policy does not apply to our educational services, including how we handle students' personal information. Please click here to read our Privacy Policy for our educational services.

Our Services may contain links towards external website, applications or services ("External Services"). For instance, our website may allow you to share content on social media through platforms other than our website. These External Services are not covered by this Privacy Policy. You have to read their Privacy Policy to understand how they handle your personal information.

As a participant of the Digital Advertising Alliance (“DAA”), we adhere to DAA’s interest-based advertising principles by providing you with enhanced notice, transparency and control of our digital marketing practices, as stated at https://youradchoices.com/principles. Please click here to be redirected to the section of this Privacy Policy which explains how we use cookies to perform interest-based advertising.

If you have any questions, concerns or inquiries regarding the collection, use or disclosure of your personal information, 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 which 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. What personal information do we collect about you, and why?

We collect information to perform interest-based advertising, to respond to your e-mails and messages, when you comment on our blog and to retrieve information on how our website is doing. We don't sell you data, and we only conduct interest-based advertising to market our products to you through audiences on social media. Keep reading this section for a detailed overview of what personal information we collect about you, and why.

• Electronic Data

Electronic data is collected automatically when you browse the Internet, so whenever you browse 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.

• Performance Data

We collect performance data such as the time and date of your visit(s), the time spent on our website, how you use our website, which pages led you to our website, unique device identifiers and diagnostic data. This is useful to understand how our website or ads are performing. Click here learn more about analytics cookies. Performance data is generally provided as aggregated data or by reference to an anonymous identifier, and does not allow us to identify you. We use analytics data to understand if we have any bugs, to understand how visitors interact with our site, to identify improvements to our Services, and for similar purposes.

• Identification Data

If you submit an inquiry to learn more about our educational services, we collect your full name, work email, work phone, your job function and the name of the school district and organization that you work for. We do this to prepare to respond to your inquiry, and to prepare proposals and sales materials for you.

• Marketing Data

We install cookies which belong to third parties, such as social media platforms, and which collect aggregated data about how you browse the web and what you like when you're browsing the web. We have a blog that allows you to create accounts and comments publicly. If you do so, our website collects this data. If you subscribe to our marketing communications (like newsletters), we'll collect your e-mails and we will know when you open our e-mails through web beacons. You can unsubscribe at any time by contacting us, or directly in the communication.

• Communication Data

If you communicate with us by email, on social media or by any other means, we collect the personal information that you share with us, such as your email address and the content of your communication so that we can respond. If you communicate with us using social media, we will have access to your publicly available information.

• Employment Data

If you apply for a job through our website, we collect the personal information identified in the form and the documents that you upload, such as your curriculum vitae. Some of our work positions require the performance of criminal background checks due to the nature of our educational services.

3. 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.

4. Do we conduct interest-based advertising?

 We conduct interest-based advertising, also referred to as targeted advertising or behavioural advertising. Retargeting means that the ads that you are being served are personalized based on your behaviour when browsing online. This is enabled through cookies and requires the processing of electronic data that is considered personal information under certain laws.

We use cookies to conduct interest-based advertising through social media. Facebook collects data about your interests, and when we pay for our ads, we can target audiences. These audiences include individuals with the interests that we selected. Facebook also installs cookies on our website which collects data about your interests. Without this advertising method called interest-based advertising, you would still get ads. They may just not be about your interests.

If you are not comfortable with this, you can opt out of interest-based advertising by managing your cookies and other tracking technologies. Click here to learn how to do this.

5. 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.

6. 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.

7.  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.

8.  With who do we share your personal information?

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

 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.

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:

Telephone
9:00 am to 4:00 pm EST
Toll-free: 1-800-282-1376

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.

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.