Cloverdale Robotics Learning Inc. is a corporation incorporated under the laws of British Columbia. When the term “CRL” or “we” is used in this policy, it means CRL Inc.
Cloverdale Robotics Learning Inc. is based in Cloverdale, Surrey BC. Protection of your personal information is essential to CRL. CRL complies with the federal Personal Information Protection and Electronic Documents Act, as well as with applicable provincial privacy legislation (the “Applicable Privacy Laws”).
“Collection” – means the act of gathering, acquiring or obtaining personal information from any source, including from third parties, by any means.
“Consent” – means a voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of the persons seeking the consent. Implied consent arises where consent may reasonably be inferred from the action or inaction of the individual.
“Customer” – means an individual who is a client at a CRL Inc..
“Disclosure” – making personal information available to other persons outside of CRL.
“personal information” – means information about an identifiable individual.
“Use” – means the handling and processing of personal information.
PRINCIPLE 1: ACCOUNTABILITY
Accountability for CRL’s compliance with the privacy principles shall rest with CRL’s Privacy Officer. This individual may delegate other individuals to act in his or her behalf. The individual will be known as the “Privacy Officer”.
CRL is responsible for all personal information in its possession or custody, including information that has been transferred to it by a third party, including personal information collected by a third party assisting us with marketing.
CRL will only disclose your personal information to a third party if it is satisfied that such party will grant a comparable level of protection to your personal information. CRL selects contractors or third parties who can guarantee that technical, organizational, and security measures will adequately protection your personal information at all times.
(a) implementing procedures to protect personal information;
(b) establishing procedures to receive and respond to complaints and inquiries;
(c) training staff and communicating to staff information about CRL’s policies and practices;
(d) developing information to explain CRL’s policies and procedures; and
(e) monitoring developments in privacy and security on a continuing basis.
PRINCIPLE 2: IDENTIFYING PURPOSES
The purposes for which personal information is collected shall be identified by CRL before or at the time the information is collected.
CRL shall collect personal information only for the purposes of operating its business including:
improvement of our Robotics & Programming Policies for Professional & School-related programs
security of the child
identifying and communicating with individuals interested in receiving information about the CRL Method, Materials, services and other marketing purposes (often referred to as secondary marketing)
complying with governmental rules and regulations;
training its staff;
operating its websites.
CRL generally uses such personal information to carry on its business and serve its customers as described above. If the business is transferred to a new owner, the personal information will also be transferred subject to the limitations of Principle 5.
The purposes for which information is being collected shall be identified by the member at or before the time the information is collected. Only information that is necessary for the purposes that have been identified may be collected. The purposes for the collection, use and disclosure shall be communicated to the subject individual.
PRINCIPLE 3: CONSENT
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except as provided by law.
Consent is required for the collection of personal information and the subsequent use or disclosure of such information. Exceptions to such requirement are specified in Applicable Privacy Laws.
When acting as a service provider to a franchisee or another organization such as a private school with respect to the collection, use or disclosure of personal information, a member of CRL shall obtain and adhere to any form of consent previously obtained by such organization, subject to the exceptions provided for in Applicable Privacy Laws.
CRL may not, as a condition for the supply of a product or a service require an individual to consent to the collection, use or disclosure of personal information beyond what is necessary for such purposes.
The adequacy of the form of consent depends upon the circumstances and the type of information that is being collected.
In principle the collection, use or disclosure of personal data concerning racial and ethnic origin, political opinions, religious or philosophical beliefs, or details about the health or sexual orientation of the individual concerned is not permitted, except when such is required or allowed by law, as these are particularly sensitive categories of personal information. Should CRL collect sensitive information about you or your child, we will require your explicit consent.
You may withdraw his/her/their consent at any time, subject to legal or contractual restrictions and reasonable notice. CRL will inform you of the implications of such withdrawal.
PRINCIPLE 4: LIMITING COLLECTION
The collection of personal information shall be limited to that which is necessary for the purposes identified by CRL. The information shall be collected by fair and lawful means.
Personal information shall not be collected indiscriminately. Both the amount and the type of information collected shall be limited to that which is necessary to fulfill the purposes identified.
PRINCIPLE 5: LIMITING USE, DISCLOSURE AND RETENTION
Personal information shall not be used or disclosed for purposes other than those for which the information was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
CRL Inc. is an incorportated company whose headquarters is located in Surrey, British Columbia Canada.
CRL may disclose your personal information to third parties who assist us in the conduct of our business. Prior to disclosing your personal information, we will ensure that such third parties will protect your personal information adequately.
Employees and contractors who have access to personal information shall only be those whose function and responsibility specifically include the handling of such personal information. The right of access is restricted according to the nature and scope of the individual function and responsibility.
Personal information that is no longer required to fulfil the primary and secondary purposes of the point of collection will be destroyed, erased or made anonymous.
PRINCIPLE 6: ACCURACY
Personal information shall be accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
This is particularly important where the information is being used to make some evaluation or judgement about the individual. The extent to which the personal information shall be accurate, complete and up-to-date will depend upon the use of the information taking into account the interests of the individual.
CRL has measures in place to ensure that your personal information that is used on an ongoing basis, including information that is disclosed to third parties, is generally accurate and up-to-date.
When appropriate, CRL communicates modifications to your personal information to contractors having access to your personal information.
PRINCIPLE 7: SAFEGUARDS
Personal information shall be protected by security safeguards which are commensurate to the sensitivity of the information.
The security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The nature of the safeguards will vary according to the sensitivity of the information. CRL will monitor security developments and re-assess the risks at regular intervals.
The methods of protection will include physical measures, organizational measures and technological measures. All personal information shall be handled on a “need-to-know” basis and each member of CRL shall be responsible for the protection of the personal information used in his, her, or their job function.
CRL shall regularly make all of its employees and contractors aware of the importance of maintaining the security of personal information.
Care shall be used in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to such information.
PRINCIPLE 8: OPENNESS
CRL shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
CRL shall be open about its policies and practices with respect to the management of personal information. Individuals shall be able to acquire information about CRL’s policies and practices without unreasonable effort. This information shall be made available in a form that is generally understandable.
The information made available must include:
(a) the correct legal name of CRL;
(b) how the individual may contact the Privacy Officer with respect to complaints or inquiries;
(c) advice that the individual can gain access to the personal information held by CRL by writing to the Privacy Officer, confirming and verifying their identity, and requesting the specified information;
(d) a description of the type of personal information held by CRL including a general account of its use;
(e) a copy of any brochures or other information that explain CRL’s policies, standards or codes; and
(f) what personal information is generally made available to related organizations.
(g) advice that the individual may refuse to allow the use of his or her data for purposes of direct marketing, which must be given no later than the time of the first inclusion in a mailing.