This website [trueleadership.ca] (the “Site”) is operated by True Leadership ("True Leadership"). True Leadership is committed to your privacy and protecting it through our compliance with this privacy policy (“Privacy Policy”). True Leadership has developed this Privacy Policy in accordance with the the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other relevant privacy laws.
Please read this Privacy Policy carefully and review it periodically for the latest information about our privacy practices. By visiting and using our website, you expressly consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Notice. If you do not agree with the practices described in this Privacy Policy, please do not provide us with your Personal Information or interact with the Site.
This Privacy Policy governs our practices to the collection, use and disclosure of Personal Information that we collect through visitors and users of Site and individuals who otherwise provide us with Personal Information (collectively, “Users”).
To better understand this Privacy Notice, True Leadership has set out some basic definitions to use when reading and interpreting it.
True Leadership has designated a Privacy Officer to be responsible for its compliance with this Privacy Policy and applicable privacy legislation. True Leadership shall make known, upon request, the title of the person or persons designated to oversee True Leadership's compliance with this Privacy Policy
Personal Information
We collect Personal Information from you when you communicate with us by using our booking form to make an appointment with us, use our contact forms to ask a question or request information about our company, or otherwise submit Personal Information to us with your communications or through our contact form. Personal information may also include information containing details as to whether you have opened our emails or how you have used our website, if we can associate that information with you. If you are a business customer or prospective business customer, Personal Information does not include your title, business address and business telephone number when we use that information to contact you in your business capacity. Further, Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any other User. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.
Non-Personal Information
True Leadership collects non-Personal Information (“NPI”) about Users when they interact with the Site or use our services. For example, we collect information about what site referred you to our website, your browser type, operating system type and version, language, and your Internet Protocol (“IP”) address. We also collect information about how you browse through our website, including logging the pages you visit and the amount of time you spend on certain pages. See the section below entitled “How does True Leadership collect, use and share NPI?” for more information.
True Leadership collects Personal Information for the following purposes:
True Leadership uses NPI in an ongoing effort to better understand and serve our customers and to improve the content and functionality of our Site.
In addition, True Leadership may use Personal Information, on an aggregated de-identified basis, for research purposes to improve our Site or services. This aggregated de-identified information does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy. For instance, True Leadership uses NPI to monitor traffic and to collect statistical data.
No NPI by itself, or together with aggregated Personal Information, can be tracked to a specific individual's Personal Information.
True Leadership respects your privacy and, unless otherwise required by law, True Leadership will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means. In certain circumstances, your consent may be implied by your actions. For example, providing True Leadership Personal Information to make an appointment is implied consent to use such information to make an appointment with us.
Where appropriate, True Leadership will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when True Leadership wants to use information for a purpose other than those identified above). In obtaining consent, True Leadership will use reasonable efforts to ensure that a User is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by True Leadership may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, True Leadership shall take into account the sensitivity of the Personal Information and the reasonable expectations of True Leadership Users. True Leadership will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, you must provide notice to True Leadership in writing.
As noted above, True Leadership does not disclose your Personal Information to third parties, except as provided for in this Privacy Policy.
We may share your Personal Information with our service providers that help us with our business operations. For example, we may transfer information with service providers who provide us with marketing and promotional services. We require our service providers to keep your Personal Information secure. In addition, our service providers may not use or disclose Personal Information for any purpose other than providing the services on our behalf unless we or they have obtained your consent.
We may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our business or as part of a corporate reorganization or stock sale or other change in corporate control.
Subject to the foregoing, only True Leadership's employees, agents, contractors, service providers (and their employees and contractors) with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about you. All such employees and contractors will be required as a condition of employment to contractually respect the confidentiality of True Leadership's Users’ Personal Information.
True Leadership will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by True Leadership.
True Leadership will disclose Personal Information without your knowledge or consent if True Leadership receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your Personal Information. If True Leadership receives a written request from a police officer or other law enforcement agency with authority to request access to your Personal Information in the course of an actual or potential investigation into a breach of a law, True Leadership's policy is to provide the requested information.
True Leadership uses cookies to enhance Users’ experiences. Users’ web browsers place cookies on their computers for record-keeping purposes and sometimes to track information about them. Cookies help True Leadership accurately understand how many consumers are visiting True Leadership's Site, how often Users visit the Site, what content Users are most interested in, and how they prefer to interact with Content on the Site. For example, a cookie will allow True Leadership to remember certain things like your Internet Protocol (IP) address (IP addresses are strings of numbers that identify senders and receivers of information sent across the Internet), your login information, the time and duration of your visits, how you navigated through True Leadership's content and where you exited the Site. To save you the time of re-entering your login information every time you come back to the Site, True Leadership may link information contained in a cookie to your email address. True Leadership does not use cookies to retrieve information from your device that True Leadership did not originally send in a cookie.
You may disable cookies using your browser's settings. Please consult your browser's help function for information on how to disable cookies. Note that if you disable cookies, certain features of True Leadership's Site may not function to its fullest potential.
Upon request, True Leadership will provide you information regarding the existence, use and disclosure of your Personal Information and you will be given access to that information. True Leadership will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, True Leadership may not be able to provide access to all of your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. True Leadership will provide the reasons for denying access upon request.
True Leadership protects your Personal Information by security safeguards appropriate to the sensitivity of the information. True Leadership will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. This includes limiting access of employees to, and the use of, your Personal Information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your Personal Information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your personal information and we require any third-party service providers to take comparable steps to ensure the protection of any of your personal information that is shared with them.
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit Personal Information to us using our website if you consider that information to be sensitive.
An individual will be able to make inquiries and/or address a challenge concerning compliance with this Privacy Policy to True Leadership's Privacy Officer.
True Leadership will maintain procedures for addressing and responding to all inquiries or complaints about True Leadership's handling of Personal Information. True Leadership shall investigate all complaints. All inquiries or complaints involving Massago's handling of Personal Information or compliance with this Privacy Policy or with PIPEDA shall be directed to True Leadership's Privacy Officer.
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If True Leadership finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
For more information, please contact True Leadership's Privacy Office as follows:
E-mail: info@trueleadership.ca
Your Personal Information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your Personal Information. However, if your Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
The Site is not directed to children under the age of 16 years. True Leadership will not knowingly collect Personal Information about a child under the age of 16. True Leadership does not allow minors (persons who are under the age of majority in their place of residence) to use the services provided on the Site.
We comply with Canada’s anti-spam legislation (CASL) and we will not send you electronic communications in contravention of this law. We will ensure that each email includes an opt-out feature and instructions on how to unsubscribe if you no longer wish to receive future emails from us. You can unsubscribe using the link included in the email or by using the contact information set forth below. If you do not expressly consent to receiving electronic communications, we will only communicate with you for the limited purposes permitted under CASL.
True Leadership has the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice to clarify our practices and to reflect new or different privacy practices, such as when we add new services, functionality or features to the Site.. Any such amendment(s) will be posted on the Site and will be effective as of the date of posting. If we make any material changes we will notify you by e-mail (sent to the e-mail address specified in your account, if any). You can determine when this Privacy Policy was last revised by referring to the date it was “Last Updated” above.