PRIVACY POLICY

This privacy policy applies to Arcitura Education Inc. including www.arcitura.com, patterns.arcitura.com and www.aitcp.org (our “Websites”) owned and operated by Arcitura Education Inc.

1) ACCOUNTABILITY
When you use Arcitura’s services, including ordering our products and services or visiting our Websites on the internet or via mobile sites (collectively, the “Services”), you entrust us with personal information (“Personal Data”). This privacy policy (the “Policy”) sets out what Personal Data Arcitura and our affiliates (“Arcitura”, “we”, “us”, or “our”) collect, and how we use it. It also describes the choices available to you regarding our use of your Personal Data and how you can access and update this information.

This Policy is currently in effect and was last updated on November 14, 2018 We reserve the right to unilaterally modify this privacy statement at any time, so please review it frequently. If we make material changes to this Policy we will notify you prior to making the changes on our homepage and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

2) IDENTIFYING PURPOSES

Personal Data we Collect

When you use our Services, you may be required to provide personal information (additional details below). Collection of certain Personal Data (particularly your payment details and contact information) is required for many of our products and services and if you fail to supply such Personal Data, we may be unable to deliver you the products and services in full.

We may collect the following Personal Data:

a. Personal information. This may include your name, your address, your contact details and academic history with Arcitura;
b. Payment Details. Payment details used to purchase our products and services such as credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services or virtual currency) and billing information;
c. Use of product and services. Information such as previous orders, feedback about your experiences and your use of our Websites;
d. Personal interests, preferences and opinions. Information about your interests, preferences and opinions such as products you are interested in and products you have bought;
e. Our interactions with you. A record of any interactions and correspondence between us, such as calls made through our call centre, any interactions you have with our instructors, staff or representatives (whether online, on the phone, or in person) and any interactions with us or posts that refer to us on social media;
f. Survey information. Your responses to surveys conducted by us or on our behalf;
g. Use of Websites, apps and social media platforms. Details of your visits to our Websites, your use of social media platforms and other information collected through cookies and other tracking technology including information that you look at (additional details below). We may also collect information about you that is publicly available online, including your social media profiles; and
h. Employment information. If you are an employee or other person obtaining products or services in relation to one of our corporate or government clients, we may collect certain information about your employment, such as your employer’s name, your professional title and your work contact information.

Method of Collection

We will collect Personal Data from you directly to the greatest extent possible. However, we may also collect Personal Data from other third parties including:

a. other persons that make orders or otherwise interact with us on your behalf;
b. our service providers and agents including without limitation our ground delivery personnel or our call centre agents who provide customer service;
c. organizations which conduct credit, fraud, and other checks;
d. law enforcement agencies, and other government or regulatory bodies;
e. providers of third party websites, apps and social media platforms.

Tracking Technologies

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

Some information is also collected automatically every time you visit our Websites (e.g., cookies and conversion beacons). We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Websites, tracking users’ movements around the Websites, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

Cookies

This privacy statement covers the use of cookies by our Websites only and does not cover the use of cookies by any third parties. Our Websites uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. This means we will continue to show ads to you across the Internet, specifically on the Google Content Network (“GCN”). This could be in the form of an advertisement on the Google search results page, or a site in the GCN.

We respect your privacy and are not collecting any identifiable information through the use of Google’s or any other third party remarketing system. Any data that is collected will be used in accordance with our own privacy policy and Google’s privacy policy.

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. We currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track”, please visit https://allaboutdnt.com for more information.

We may also partner with other third parties from time to time to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Websites and other sites to provide you advertising based upon your browsing activities and interests.

3) CONSENT

Use of Personal Data

When you use our Services, or visit our Websites, you provide us with your implied consent to use your Personal Data to fulfill your request. We may also use your Personal Data for the following purposes:

a. Provide products and services. To provide our products and services to you and to process and administer your orders, to contact you about your orders and to send you service-related communications, to deliver of benefits and services associated with your order, to identify and verify your identity in connection with the services we provide, or to provide or facilitate any special arrangements you may have asked for;
b. Customer support. For customer support purposes such as responding to your enquiries and requests, providing assistance to you in relation to issues such as order fulfillment issues and delays;
c. Marketing purposes. For providing you with certain marketing communications (as explained in more detail below);
d. Social interactions. To administer campaigns, contests and sweepstakes conducted by us when you choose to participate in them, including disclosing the winners of any such contest;
e. Product and service improvement. For the purposes of improving our products and services for the benefit of our customers generally, including to ensure that our Websites and web pages (including social media pages) function correctly and in accordance with your preferences and circumstances;
f. Special discounts. We offer special discounts and promotions from time to time. To assess your eligibility and ensure that your order is correctly processed we may need to record additional information at the time of ordering; and
g. Legal and administrative purposes. For legal and administrative purposes such as verifying and processing payment, screening against fraud, screening against abusive orders, money laundering and other criminal or unlawful activities, accounting, billing and audit purposes, developing, maintaining and testing our systems, for claims handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.

Marketing

We may use Personal Data for marketing and promotional purposes, including (i) for sending or showing you updates on latest news, offers and promotions in connection with our products and services (and the products and services of our group companies and third parties) (ii) for sending or showing you joint marketing offers about our services and packages, contests and sweepstakes, and ancillary services; or (iii) for tailoring and tracking your interactions with internet banner advertisement and links from third party websites to our Websites.

We may also use Personal Data to analyse our customers’ preferences and market trends and derive insights, which we may use to tailor the types of products and offers that we present to our customers. This may involve us combining Personal Data that we hold about your use of our services with information that we have collected about your web usage. We may also combine information that we have collected about you with information that we have collected about our other customers in order to derive these insights and establish market trends.

We may communicate marketing and promotions to you by mail, telephone, or online (including by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.

You have the right to ask us not to process your Personal Data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal data for direct marketing purposes by following the opt-out instructions contained in the relevant communications or updating your email subscriptions.

We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you. You may also opt out by contacting us at our Address set out below.

Please note that if you choose to unsubscribe or opt out of marketing communication, we will still send you communications about your orders with us and any other services that we provide to you. Where you are an account holder, you will also continue to receive administrative emails, account and/or order summaries and updates to our services.

Our email offers

When you use our Services you are added to our email list that will be used to contact you occasionally with offers that we feel will be of interest to you. If you do not want us to contact you with offers, you may withdraw your consent at any time. If you later change your mind it is just as simple to opt back in to the email offers of your choice. In addition, all emails sent to you by us contain simple instructions telling you how to “unsubscribe.”

4) LIMITING COLLECTION
We only collect Personal Data to the extent necessary to fulfill the purposes set out in section 3 above.

If a third party, including a family member, friend, or work colleague seeks to make an order on your behalf, that party will be asked to provide us with the same Personal Data that we would normally collect from you directly in order to complete your transaction. Unless and until we are advised otherwise, we consider that such third party has your consent and authorization to provide us with your Personal Data, to receive promotional and service emails, and to make orders (and changes thereto) on your behalf in accordance with this Policy. Please note that the collection, use and disclosure of your Personal Data by a third party is subject to your dealings with them and any applicable privacy policies and practices they may have.

If a third party who has used our Services on your behalf or who otherwise has your full name and order reference contacts us and seeks information on your order or wishes to make changes to it, we will disclose your order information and allow such third party to make changes as we will conclude that you have given them your consent to do so. If you do not want an individual to be able to obtain information on or make changes to your order, you should not share your order reference with them.

If you provide us with information about other individuals, you must tell those individuals and let them know where they can find a copy of this Policy.

5) LIMITING USE, DISCLOSURE AND RETENTION
We do not sell your Personal Data to third parties. Other than as set out herein, we will not use or disclose your Personal Data for purposes other than those for which it was collected without your explicit consent or as required by law.

We use contractual and other means to ensure that your Personal Data is afforded protection that meets the requirements of privacy legislation whenever one of our third party service providers is used to perform services on our behalf, including without limitation, services relating to information technology, marketing, data processing and storage, research, conducting surveys and customer relations.

In certain circumstances, we may disclose your Personal Data to third parties as follows:

a. Our service providers. We will permit our third party service providers, including agents and contractors and our affiliates, to use your Personal Data on our behalf for the purposes set out in section 3. Examples of such third parties include our ground delivery agents who assist you with product delivery, operators of our IT systems and call centre agents. We may also disclose your Personal Data to third parties in order to facilitate any special arrangements that you may have requested;
b. Third parties to facilitate your order. In order to facilitate and administer your order, we may transfer your Personal Data to third parties such as other persons who interact with us on your behalf;
c. Our third party partners, for marketing purposes. We may disclose your Personal Data to third parties so they can provide marketing services or conduct marketing or social interaction activities on our behalf such as campaigns, contests, sweepstakes, market research, customer surveys and data analytics to help us improve and tailor our marketing activities, products and services. Subject to us having obtained appropriate consent from you, we may also disclose your Personal Data to our third party marketing partners in order that they may market their products and services to you. In some cases, our third party service providers are located outside Canada. As such, your Personal Data may be processed or stored in other countries. In certain circumstances, our third party service providers may be required to disclose information to government authorities, regulators, courts, or law enforcement in those countries. Customers who do not wish to be contacted for research, marketing or survey purposes should advise us by contacting us at the Address provided below;
d. Corporate or government clients. For employees or other persons obtaining products or services in relation to one of our corporate or government clients, we will disclose your order details and information concerning your use of our service to our corporate or government clients; and
e. Government and regulatory bodies and other individuals, bodies and organizations. We may disclose your Personal Data to governments and regulatory authorities and bodies and to other individuals, bodies and organisations such as law enforcement bodies, legal advisers, organisations which conduct credit, fraud and other checks, and other individuals, bodies and organisations for the purposes of complying with our legal obligations. We may also disclose your Personal Data as required by law when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice on our Websites of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data, or to any other third party with your prior consent to do so. We may also disclose your Personal Data to such individuals, bodies and organisations for reasons of safety and security, to enable us to provide our products and services to you and otherwise for legal and administrative purposes.

We use contractual and other means to ensure that your Personal Data is afforded protection that meets the requirements of privacy legislation whenever one of our third party service providers is used to perform services on our behalf, including without limitation, services relating to information technology, marketing, data processing and storage, research, conducting surveys and customer relations.

Information Retention

We will retain your Personal Data for as long as is necessary for the purpose(s) for which it was collected and any other permitted related purpose (for example where we are required to retain Personal Data for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). We will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Our retention periods may vary depending on the purposes for which your Personal Data was collected. Once your Personal Data is no longer needed, it is either irreversibly anonymized (and the anonymized Personal Data will be retained) or securely destroyed.

6) ACCURACY
We will take reasonable efforts to ensure your Personal Data is accurate, complete and current. However, we will not routinely update your Personal Data unless it is necessary to fulfil the purposes set out in section 3.

When you use our Services or create an account with our Websites, if applicable, you can ensure that the Personal Data we hold is accurate and up to date. To help us do this, you may wish to notify us of any changes to your Personal Data.

7) SAFEGUARDS
No data transmission over the internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, organizational and technological safeguards to protect your Personal Data in accordance with the requirements of data protection legislation.

All Personal Data we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using Personal Data and restrict access to your Personal Data to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of. In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our Websites, we ask you not to share that password with anyone.

Personal Data is encrypted as it travels over the internet. Depending on your web browser you may see a secure webpage indicator. The use of Secure Socket Layer protocol (SSL) allows all Personal Data, such as your payment card number, to be encrypted as it travels from your computer to our order system. Once received, the information is unencrypted and processed in the same way as a payment card transaction placed via the telephone.

We treat your Personal Data as strictly confidential, and we have taken the appropriate technical and organizational security measures against loss or unlawful processing of this information. To this end, we use several security techniques including secure servers, firewalls and encryption, as well as physical safeguard of the locations where data is stored. If you have any questions about the security of your Personal Data, you can contact us at our Address set out below.

8) OPENNESS, INDIVIDUAL ACCESS AND CHALLENGING COMPLIANCE
Should you have any questions regarding this Policy or concerns with respect to our compliance with the requirements of applicable privacy legislation, you may contact us at the following address (our “Address”):

Arcitura Education Inc.
Attention: Privacy Officer
Address: 202 – 55 Gostick Place, North Vancouver, B.C. V7M 3N2
Telephone: (604) 904-4100
Facsimile: (604) 904-4465
Email: info@arcitura.com

With certain limited exceptions, you have a right to access your Personal Data that we hold, including how we have used or are using your Personal Data and whether we hold or process any of your Personal Data on behalf of a third party. To request this information, please contact us in writing at our Address provided above. We will endeavour to provide any help that you need to prepare a request for access to your Personal Data. Part of this process may involve us requesting you to supply enough information to enable us to account for the existence, use and disclosure of the Personal Data. 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, and information that is subject to solicitor-client or litigation privilege.

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