Introduction and Acceptance
Welcome to the ChallengeU interactive educational and knowledge transfer services (the “Services”) which may be accessed from our websites including but not limited to www.challengeu.com, www.challengeu.ca, www.didacti.com, and www.competenceplus.co, and any and all subdomains and subpages thereof (the “Websites”). We hope you enjoy your visit to our Websites and / or use of the Services.
Who We Are
The Websites and Services are owned and operated by 9249-9219 Québec Inc. (“ChallengeU”), a duly-incorporated corporation located at 500-160 rue Saint-Viateur Est, Montréal, Québec, Canada, H2T 1A8. Where this Policy refers to “ChallengeU” it may refer to 9249-9219 Québec Inc. and / or its affiliates, and / or their respective shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to ChallengeU and / or its Representatives. In this Policy, a Website visitor or Services user may be referred to as “you” or “your”.
If you have any questions about the Policy or if you wish to inquire about and / or access any Personal Information ChallengeU holds about you, please contact:
ChallengeU Privacy Officer
ChallengeU Privacy Officer
500-160 rue Saint-Viateur Est
Our Respect for Your Privacy and Protection of Personal Information
ChallengeU takes your privacy and security of Personal Information very seriously. We have provided a secure environment and this strict Policy that describes the limited ways the information is used and the limited access to such information.
This Policy covers the treatment of personally-identifiable information, i.e. any information that identifies an individual, or can be used in conjunction with other information to identify an individual (“Personal Information”), when you voluntarily submit this information and other information gathered by ChallengeU when you are using or accessing the Websites or Services. This Policy also covers ChallengeU’s treatment of any Personal Information that ChallengeU may share with its business partners or other third parties under very limited circumstances.
This Policy does not apply to the general practices and treatment of information (whether personal or not) by third parties that ChallengeU does not own or control, including but not limited to any third-party websites or services that you elect to access through the Websites or Services or via a link from the Websites or Services (“Third-Party Services”), or to individuals that ChallengeU does not manage or employ. While we attempt to facilitate access or link only to those Third-Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Services. We encourage you to carefully review the privacy policies of any Third-Party Services you access.
Finally, this Policy does not cover any Personal Information you send to ChallengeU via any non-secured mode of communications such as instant messenger, Facebook or Twitter, as communications via these methods may be subject to interception, loss, or alteration. While we welcome your comments and suggestions sent to us in this manner, we encourage you to carefully examine what Personal Information you send to ChallengeU via these methods.
We Do Not Collect Personal information from Users Under 13 Years of Age
When we collect Personal Information, we do not know the age of our users, and we would never knowingly collect Personal Information from someone under 13 years of age. If we discover we have inadvertently gathered Personal Information from a minor under 13 years of age, we will take the necessary measures to promptly delete such Personal Information from our records.
We Do Not Collect Your Personal Information Without Asking You
ChallengeU does not, as a matter of course, gather any of your Personal Information while you are visiting a Website or using the Services, unless you are asked to provide such information, for example by submitting your contact information or signing up for an account. Personal Information is only gathered with your informed consent. Where you have provided Personal Information, it will only be used for the stated purpose or use, as described in the next section of this Policy.
The Personal Information We Collect and What We Use It For
The following is an exhaustive list of Personal Information collected from you, or from third parties about you, when you visit a Website or use the Services and what we use it for. You acknowledge that you are submitting this Personal Information with your informed consent.
“Contact Information”. You may use a contact form on a Website to contact ChallengeU and submit your name and email address. We only use this Contact Information to reply to your inquiry.
“Newsletter Information”. You may sign up for our newsletter by submitting your name and email address. We only use this information to sign you up for, and to send you, the newsletter. For more information about how we treat your Newsletter Information, please see the Email Communications section further in this Policy.
“Account Information”: Users of the Services will be required to submit certain information to create an account in order to use the Services. This Account Information may include (depending on the Services used) your name, your email, your phone number, certain demographic information, a student number, a photograph, and any Personal Information that may be on identification documents submitted to us. Some of this Account Information may come from third parties, specifically your school board. This Account Information is used to verify your identity, to manage your account, to verify your credentials for logging-in to the Services, to communicate with you information about your account, and to communicate with you information about the Services.
“Billing Information”. If you are making a payment in the Services, for example a purchase of certain content, you will be required to enter the following information: your credit card number, credit card expiry date, credit card security (CVV) number, and billing address. Billing Information is only used to process the credit card transaction for your payment. The Billing Information is never stored on servers controlled by ChallengeU. For more details regarding the treatment of your Billing Information, please see the Secured Payments section further below in this Policy.
How We Protect Your Personal Information
ChallengeU uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. We have implemented very strict technical and organisational procedures for ensuring that, by default, only Personal Information which are necessary for each specific purpose are used by us. These procedures prevent your Personal Information from being lost; or used or accessed in any unauthorised way. In addition, ChallengeU uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to host the Websites and run the Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, ChallengeU uses Amazon AWS, a recognized leader in secure data, for hosting of the Website and Services, and storage of information (including Personal Information). Please note that these third parties may not be located in your home jurisdiction – see the “Transfer of Personal Information Outside Your Home Jurisdiction” section further in this Policy for more information.
We Only Disclose Your Personal Information to Third Parties in Very Limited Circumstances
Except as provided in the next paragraph and the next three sections in this Policy, ChallengeU does not divulge any Personal Information gathered via the Websites or Services to third parties. Moreover, ChallengeU does not sell, rent, trade or license any Personal Information regarding its users to third parties. Only the Representatives and subcontractors of ChallengeU (or of ChallengeU’s affiliates’) are responsible for the management and development of the Websites and Services, and only these individuals have access to the information collected there. These Representatives and subcontractors all have been instructed to comply with the Policy and are under a contractual duty to do so.
Transfer to Third Parties with Your Consent
We transfer the following Personal Information to the following third parties as part of the regular provision of the Services:
To school boards. When you are using the Services in order complete certain requirements for earning official school credits, we will share Personal Information and your related results with your school board. If this is the case, by using the Services you consent to such transfer.
For advertising purposes. ChallengeU may show you advertisements around the web, using a cookie installed by each advertising network. ChallengeU currently uses Google AdWords and Display Network and by using the Services you consent to this use. Specifically, ChallengeU uses the remarketing features of interest-based advertising of Google AdWords that delivers you advertisements that will be of particular interest to you, based on your browsing and activity history at the Websites or Services. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these ads around the web. You may prevent this type of advertising by deleting the appropriate Google cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google advertising by following Google’s instructions. ChallengeU also advertises using Facebook Custom Audience, to display advertisements to you on Facebook that will be of interest to you, and by using the Services you consent to this use. Facebook may collect or receive information from the Services and other websites or services and use that information to provide measurement services and targeted ads. If you do not want to receive such Facebook advertisements, please contact us by email at firstname.lastname@example.org. We also use Bing Ads from Microsoft, which you can opt out of at this link.
Email Communications with You and Compliance with Anti-Spam Laws
ChallengeU currently uses MailChimp to send out and manage our newsletter and marketing emails. Personal Information is transferred to MailChimp in order for our email communications to function properly. Your Personal Information is only used for the proper sending out of the emails; MailChimp does not use this Personal Information for any other purpose and will not transfer or sell your Personal Information to any other third party. You may unsubscribe from receiving these emails from us at any time by following the link at the bottom of any email sent to you.
ChallengeU also uses a third party, Postmark, to send out transactional emails that are required to use the Services. Again, your Personal Information is only used for the proper sending out of the emails; Postmark does not use this Personal Information for any other purpose and will not transfer or sell your Personal Information to any other third party.
ChallengeU’s practices with regards to its email practices are designed to be compliant with anti-spam laws, specifically the law unofficially called “CASL”, or Canada’s Anti-Spam Law, as well as the American CAN-SPAM Act. If you believe you have received email in violation of these laws, please contact us using the contact information further up in this Policy.
When You Make Secured Payments
The Non-personal Data We Gather for Very Limited Purposes
ChallengeU automatically collects certain information using third-party analytics programs including Google Analytics to help us understand how our users use the Websites and Services, but none of this information identifies you personally. For example, each time you visit a Website or use the Services, we automatically collect your IP address, browser and computer type, access times, the web page from which you came, and the web page(s) you access (as applicable). We use information collected in this manner only to better understand your needs and the needs of the Websites and Services and their users in the aggregate. ChallengeU also makes use of information gathered for statistical purposes to keep track of the number of visits to the Websites and Services and the specific pages on the Websites and Services with a view to introducing improvements.
Your IP address and other relevant information may be used in order to trace any fraudulent or criminal activity, or any activity in violation of any Terms of Service or any other agreement signed with ChallengeU.
Aggregated Information and its Uses
In addition to the information collected by the analytics programs as described in the previous section, we may also generate, use and disclose aggregated and / or anonymized information and statistics about the Services and Services users for the purposes described in this section. No user of the Services will be individually identifiable from these aggregated and / or anonymized information and statistics.
Marketing and strategic business purposes. We may use aggregated and / or anonymized information to help market our Services or to plan for future business activities.
Improving the Services. We use machine-learning and experimentation to use aggregate and anonymized data from Services users in order to improve the Services. The results of such experimentation will be shared with a third party, specifically the National Research Council of Canada. By using the Services, you consent to such use, and the transfer of the results, which cannot identify you in any way.
Your Rights to Verify, Correct and Delete the Personal Information We Hold
You have the right to: (i) verify what Personal Information ChallengeU holds about you; (ii) ask for your Personal Information to be corrected or updated; and (iii) withdraw your consent to the use by ChallengeU of your Personal Information and have it deleted from our records. If you wish to inquire about and verify and / or correct Personal Information ChallengeU holds about you, or if you wish to have all your Personal Information permanently deleted from our records, please contact us using the contact information further up in this Policy. Please note that deletion of your Personal Information may make it impossible for you to use the Services, or certain portions thereof. If you request deletion of your Personal Information, ChallengeU reserves the right to retain some of your Personal Information for a reasonable time in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.
Tracking Technology (“Cookies” and Related Technologies)
ChallengeU uses tracking technology (“cookies”) and other related technologies such as pixels or web beacons on the Websites and in the Services and by visiting or using a Website or the Services you agree to their use. Cookies are small text files placed on your hard drive or memory of your computer or device when you visit a Website or use certain services, in order to track use and to improve the user experience by storing certain data on your computer or device. The Services use “session cookies,” which improve your user experience by storing certain information from your current visit on your computer or device.
to facilitate your signing-in to the Services;
to provide you with customized content;
to keep track of preferences you specify while you are using the Services;
to provide general internal and user analytics;
to conduct research to improve the content of the Websites and Services;
advertising cookies and related technologies are used to display advertisements as described earlier in this Policy;
to facilitate payment processing;
to assist in identifying possible fraudulent activities.
Transfer of Personal Information Outside Your Home Jurisdiction
Services users may access certain of the Services from any country in the world. However, the Services are not intended for users in the European Economic Area (“EEA”). Anyone using the Services from the EEA does so at their own risk, and the risk to their Personal Information.
ChallengeU and its third-party vendors, including service providers and hosting partners, are located in Canada and the United States. You acknowledge that ChallengeU and our third-party vendors may be located in jurisdictions or countries where the privacy laws may not be as protective as those in your home country, state, province or other governmental jurisdiction, and consent to the transfer of your Personal Information to such countries.
Services users in Canada will have their Personal Information Stored in Canada, while Services users in the United States will have their personal Information stored in the United States.
There are Risks When Using the Internet
Despite ChallengeU’s best efforts to ensure that third parties will not access or obtain your Personal Information, complete confidentiality and security cannot currently be guaranteed on the Internet. Communication via the Internet is subject to interception, loss, or alteration. You acknowledge and agree that ChallengeU cannot be held responsible for damages resulting from the transmission of confidential information or Personal Information over the Internet and that such communications are at your own risk.
When We Link to Third-Party Websites
When You Post on Users’ Accessible Areas
Users of certain Services may post, submit and exchange content and information on areas of the Services that are accessible to other users, if they decide to do so. You should exercise caution if you choose to disclose Personal Information in a publicly accessible area. You are solely responsible for any Personal Information that you disclose and disseminate on publicly accessible areas of the Services.
We Are Compliant with Privacy Laws
This Policy and ChallengeU’s practices in general are designed to be in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”, S.C. 2000, c. 5) and Quebec’s An Act Respecting the Protection Of Personal Information in the Private Sector (R.S.Q. c. P-39.1). If you have any questions regarding this compliance, please contact us using the contact information further up in this Policy.
Modifications to this Policy
ChallengeU reserves the right, at any time and without prior notice, to modify or replace any of the Policy. Any changes to the Policy can be found at this URL. It is your responsibility to check the Policy periodically for changes. Your use of a Website or the Services following the posting of any changes to the Policy constitutes acceptance of those changes. If we make any substantial changes to the Policy that materially affect the way we treat your Personal Information, we will use commercially reasonable efforts to notify you by posting a prominent notice when you log in to the Services for the first time following those changes and / or posting a prominent notice on the Websites.
Copyright 2018, ChallengeU