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.
(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.
(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
(c) Share With a Friend Function
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
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.
10. Contact Us
By email: firstname.lastname@example.org
401 Richmond St West
September 2, 2016