Privacy Policy

Paddle Inc. (“Paddle”) is committed to transparency in the collection and use of your personal information.  The Privacy Policy below describes how we collect and use personal information, and the circumstances under which we may share this information. This Privacy Policy applies to the privacy practices of Paddle on its website, located at http://www.mypaddle.co/ (the “Website”) and to Paddle’s related interactions with users of the Website.  

1.    Collection of Information

Paddle is an interactive career development and learning web platform that provides individuals with tailored recommendations related to their careers based on the results of assessment completed by the individuals (the “Services”). Paddle may collect the following types of information:

(a)    Account Information: 

To use the Services, you need to register for a Paddle Account (the “Account”) through our Website.  During the registration process, you may be asked to provide us with the following information, including but not limited to your full name, your employment status, past employers, sector preferences, the university you attended, your graduating year, and email address. You may also be asked to choose a username, password and security questions.  

In registering for an Account, you can choose to provide your social media login information and password through platforms such as Facebook or LinkedIn. If you do so, you authorize us to access certain social media account information (consistent with your social media privacy settings), including but not limited to your profile information, full name, username, email address and full physical address. All such information is provided directly by the social media platform, whose use of your personal information will be subject to its own privacy policy and terms of use. 

(b)    Information Related to the Assessments

To enable us to provide you with tangible recommendations related to your career, users are invited to complete various assessments, including motivation and personality assessments (“Assessments”). Through the Assessments, we collect information about your motivations to provide you with feedback on what drives you, top sector matches, recommendations and tailored career advice.  

(c)    Information Related to the Recommendations

In addition to the information collected from the assessments, Paddle also uses the Account information and preferences selected to provide personalized recommendations and tailored career advice.

We collect information on how you interact with the personalized recommendations, including but not limited to whether you accepted, deleted, followed, completed or shared the personalized recommendation.  

(d)    Payment Processing Information

When you pay for the Services, we collect payment information from you such as credit card information for processing by our third party payment service provider.

We do not retain any payment processing information or any financial information such as credit card numbers. All such information is provided directly to our third party processor, Stripe Payments Canada Ltd., whose use of your personal information will be subject to the payment processor's own Privacy Policy and Terms of Service.

(e)    Information We Collect When You Visit Our Website

When use a computer, tablet, smart phone or other device to access our Website, we may collect information about the device and how you use it.  This information may include the type of device, your operating system, your browser (for example, whether you used Internet Explorer, Firefox, Safari, Chrome or another browser), your internet service provider, your domain name, your internet protocol (IP) address, your device identifier (or UDID), the date and time that you accessed our service, the website that referred you to our website, the web pages you requested, the date and time of those requests, your physical location and your interaction with in the website. 

2.    Use of Information

We use the information described above to:

(a)    provide the Services to you;
(b)    fix, maintain, enhance and modify the Services;
(c)    communicate with you; 
(d)    comply with legal and regulatory requirements;
(e)    promote our products and services; and
(f)    provide you with recommendations, offers and advertisements products and services from third parties that might interest you. 

We may use information for any purpose if we anonymize it so that it no longer reasonably identifies you.

3.    Disclosure of Information

We may transfer or disclose information as follows: 

(a)    Service Providers Arrangements

Your information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf.  Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes. 

Your information may be stored and processed by us, our affiliates and other third party service providers in the United States, European Union or other foreign jurisdictions.  In the event that personal information is transferred to the United States, European Union or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.

(b)    Educational Institutions, Career Coaches, Employers and Other Third Parties

You can direct us to disclose and share your Assessment results and / or other data or information from your Account (including, but not limited to, your usage data) with other third parties, such as your educational institution, your career coach, your professor, your employers or your counselors. Once you direct us to share your data with a third party, that data is governed by the third-party’s privacy policy. You can revoke your consent to share with the third party at any time by contacting us. 

(c)    Share With a Friend Function

You have the ability to share your Assessment results and / or other data or information from your Account with your friends through email or social media. By sharing your Assessment results and / or other data through social media, you are authorizing us to share information we collect from and about you with the social media service provider, other users, and your network of contacts on the social media service, and you understand that the social media service's use of the shared information will be governed by the social media service's privacy policy and terms of use.

If you choose to share your Assessment results or other data or information from your Account through email, we will collect your name and email address, as well as the name and email address of your friend (the recipient). We do not use the names or email addresses submitted in these circumstances for any other purpose without the consent of you or the email recipient to do so. To fulfill our obligations under the Canadian Anti-Spam Legislation ("CASL”), please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the message from you.

(d)    Legal and Compliance

We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law or legal process.  Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

(e)    Sale of Business

Personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Paddle or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

(f)    Aggregated Data

Paddle may share or sell aggregated data that does not identify you with third parties and the public in a variety of ways.  When we provide this information, we take technical measures to ensure that the data does not identify you and cannot be associated back to you. 

4.    Safeguarding and Retention of Personal Information

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure.  We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

5.    Access to Personal Information

You have the right to access, update and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law.  You can access and modify your personal information from your Account.  Alternatively, you may request access, updating and corrections of inaccuracies in other personal information we have in our custody or control by emailing or writing to us at the contact information set out below.  We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

6.    Cookies and Other Tracking Technologies

We use cookies and other tracking technologies for the following purposes: (i) to operate our Website; (ii) to provide you with offers that may interest you (including on third-party websites); (iii) to personalize the content we present you on our Website, (iv) to provide or improve our Services, and (v) to understand how our Services function and are used. Some cookies exist only during a particular session and some are persistent over multiple sessions over time. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features. 

7.    Do Not Track

Most web browsers include a “do not track” setting. However, there is a lack of certainty or consistency with respect to what impact that setting should have on the information collected or on a user’s browsing experience. Accordingly, and consistently with respect to the operation of many websites, if you enable that setting, it will not change what information is exchanged with your computer, or how that information is used, when you visit our Website.

8.    Third Party Websites

The Website may contain links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our service and go to another site. During this process, another entity may collect personal information from you.

9.    Updates to the Privacy Policy

We may update this Privacy Policy to reflect changes to our privacy practices.  We encourage you to periodically review this page for the latest information on our privacy practices.

10.    Contact Us

Paddle welcomes your comments and questions regarding this Privacy Policy and the use of your personal information. To respond to your request, we may ask you for your full name, email address and phone number. If you have questions or concerns please contact our Privacy Officer:

By email: help@mypaddle.co

By post:
401 Richmond St West
Unit 365
Toronto, ON
M5V 1X3

September 2, 2016