Published on October 3, 2023
- The kind of Personal Information we collect from you;
- How we use your personal information and with whom we are likely to share it;
- The options you have when it comes to us collecting, using, and distributing information;
- The security procedures we implement in order to protect the information we collect against theft, misuse, losses and unauthorized alterations.
- How you can correct outdated or inaccurate information.
Last update: 2023/10/30
1. Security Measures
Because Workleap cares about the confidentiality of its commercial data and the privacy of the personal information provided by users of its Website, it has designed and implemented security measures aimed at preventing unauthorized access to (and disclosures of) such data and information, which can be found on the Security page of the website.
Although Workleap spares no reasonable efforts in order to protect every piece of personal information you provide, no electronic data transfer through the Internet is 100% secure. Consequently, it proves radically impossible to store electronic data in a way that makes it completely impervious to cyber attacks, and we cannot in any way represent or warrant that your personal information will be perfectly safe at all times.
3. Geographic Tracking
All Instructors allow Workleap to pinpoint their exact geographic location for billing and taxation purposes. By using Workleap, Instructors agree never to provide false or misleading information about their geographic location. Workleap expressly disclaims any form of liability should the dispositions of this section ever be breached.
4. Data Collection
In order to better understand and satisfy the needs of those who use its Platform and Website, Workleap collects data and information likely to identify them personally. At the time an account is created or training programs are purchased, Workleap may collect some or all of the following personal information: first name, last name, country, state, e-mail address – as long as they may help us identify or contact you.
In addition to the information collected by Workleap, other personal information might be required by Instructors at the time accounts are set up by Other Users, such as first name, last name, country, state and e-mail address. In fact, Other Users agree and accept that such information will be collected by Instructors (through the use of the Platform) and subsequently stored by Workleap.
Some platforms may ask for additional information when a user account is created, the exact fields are not listed here.
5. Use and Disclosure of Information
Workleap relies on Google Analytics while collecting and using anonymous information which consist of data not likely to identify any specific individual. It also allows the administrators of a Workleap tenant to link any Google Analytics account of their own choosing.
Workleap may, in addition to Google Analytics, retain the services of other external companies which, in its opinion, are able to provide services such as website hosting and data analysis. In so doing, Workleap may disclose to such service providers listed in Schedule 1 hereto, certain information likely to identify you personally. You hereby agree to the disclosure and sharing of your personal information in such a context and for such purpose.
Notice to Instructors
You may only use information you possess about Other Users in order to satisfy statistical or marketing requirements which are directly related to the training you provide. You may neither use such information for any other purpose nor disclose it to (or share it with) third parties.
In addition to the obligations of privacy imposed upon you by the provisions of the Act respecting the protection of personal information in the private sector or of the Personal Information Protection and Electronic Documents Act, their regulations, and any other law, rules, or regulations which may find application, you must ensure that all Personal Information about Other Users that Workleap makes available to you through its Website remain private and confidential at all times.
6. Legal Bases for Processing Personal Information
Pursuant to applicable privacy laws, Workleap collects and processes Personal Information about individuals under a variety of legal bases, depending on the reason for such collection or processing. Workleap shall only collect, process or use Personal Information where:
- Personal Information is required to provide the Website and all services ancillary to the proper functioning of the Workleap LMS, such as support services, to provide a personalized experience, and to ensure the safety and security of the Workleap LMS;
- The User gave Workleap consent to use Personal Information for a specific purpose (including for a purpose listed under sections 4, 5 and 7 hereof);
- Processing of Personal Information is necessary to comply with a legal obligation;
- Processing of Personal Information is warranted by a legitimate interest of Workleap (insofar as this legitimate interest is not overridden by the interests of the data subject) or to protect Workleap’s legal rights and interests.
7. Other Instances of Data Collection
Whenever you visit the Website, we may collect (and store within log files) certain information not likely to identify you personally, such as a domain name, the identity of the web host through which you access the Internet (aol.com or unh.edu, for instance), the type of operating system and web browser you use, the days and times at which you access the Website, the Internet address of the website from which you log on, the website you visit right after you log out of your account, and the number of times you “clicked” while you were connected to the Website. Such data is collected for the purpose of analyzing trends, optimizing the management of the Website, and collecting a wide array of demographic information to be used on a global scale. We may also (i) determine the version of your web browser in order to display the most recent version of our web pages, and (ii) use data collected about our Users in view of supplying customized content, advertisements, products, and services, of enhancing your surfing experience, and of performing a variety of interval checks.
Workleap’s web pages and electronic communications may contain small images known as “web beacons” (and, albeit less often, as “invisible pixels”), which allow us to collect and track certain pieces of specific information about our Users, such as the type of device requesting a web beacon, the IP address of the computer or device to which a web beacon is transmitted, and the precise moment at which a web beacon is seen. Although some web beacons may remain invisible to a User, most electronic images spotted as part of a web page or an e-mail (including all HTLM content) can act as a web beacon. We might use web beacons to determine how many individuals visit our web pages or to categorize the surfing habits of Users on our Website. We may also insert web beacons within the e-mails we dispatch in order to assess how many messages were actually read and/or elicited some kind of reaction. Last but not least, we rely on web beacons to compile statistics about the use of our Website. In no circumstances, however, will we link information obtained through the use of web beacons to personal data you provided to us while registering and/or creating an account.
8. Sharing and Transferring of Personal Information
Workleap will not sell, rent or trade Personal Information to any third party. However, Workleap may share or transfer Personal Information when authorized and/or required by law or as follows:
8.2. Service Providers. Workleap may grant access to Personal Information to third-party service providers in connection with the performance or the improvement of the Website. Before transferring any Personal Information with any of its third-party service providers, Workleap will ensure that the third party maintains data management practices for maintaining the confidentiality and security of Personal Information and preventing unauthorized access which comply with applicable industry standards and privacy laws.
8.3. As Permitted or Required by Law. Workleap may disclose Personal Information as required by applicable law or by proper legal or governmental authority. Workleap may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Workleap may also release certain Personal Information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or safety of others and itself, in accordance with or as authorized by law. In the event Workleap receives a governmental or other regulatory request for any Personal Information, Workleap will promptly notify Users, unless it is prohibited to do so, in order that Users shall have the option to defend such action. Workleap shall reasonably cooperate with Users in such defense.
8.4. Business Transaction. Workleap may disclose Personal Information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, Personal Information will remain protected by applicable data protection laws. In the event the transaction is not completed, Workleap will require the other party not to use or disclose the Personal Information received in any manner whatsoever and to delete such Personal Information.
10. Data Retention
11. Updating your Information
You are solely responsible for keeping up-to-date the information you provide at the time your account is created as well as the data you rely on in order to secure payments (if any). Consequently, you shall be solely responsible for any losses, damages, and/or expenses that you, Workleap, or any third party could incur on account of the fact that you provided false, incomplete, incorrect, or inaccurate information or data.
12. Data Incidents Involving Personal Information
Workleap shall promptly notify Users of a data breach, of a loss of data or of a failure of Workleap’s security program:
- (a) which has resulted or is suspected to have resulted in the loss, unauthorised access, disclosure, use or acquisition of Personal Information (including hard copy records); and
- (b) which, in Workleap’s opinion, presents a real risk of significant harm to individuals whose Personal Information is impacted (“Data Incident”).
While the initial notice may be in a summary form, a comprehensive written notice shall be given to Users within the legally required timeframe, where applicable. The notice shall summarize in reasonable detail the nature and scope of the Data Incident (including each data element type) and the corrective action taken or to be taken by Workleap. Officevibe shall promptly take all necessary and advisable corrective actions, and shall cooperate with Users in all reasonable efforts to mitigate the adverse effects of Data Incidents and to prevent their recurrence.
13. Legal Rights Regarding Personal Information
Workleap relies on the legal bases described under section 6 hereof to process Personal Information. Subject to applicable laws, all Users have the right to: (i) access and rectification or erasure of Personal Information, including erasure and deletion of their profile on the Workleap LMS, except to the extent that Workleap may need to retain certain Personal Information, including for record keeping purposes or to comply with legal obligations; (ii) restrict or object to Workleap’s use of Personal Information (though, in some cases, this may mean no longer using the Website) where Workleap is relying on a legitimate interest (or those of a third party) and there is something about User’s particular situation which impacts on User’s fundamental rights and freedoms; (iii) lodge a complaint with their local data protection authority; and (iv) data portability. Users will not have to pay a fee to exercise such rights, however, Workleap may charge a reasonable fee or refuse to comply if the request is unfounded, repetitive or excessive.
14. Modifying your Information
All personal information collected about your use of the Website will be saved and stored on secure data servers controlled by Workleap and housed either within Workleap’s own business offices or installations owned and operated by its service providers.
Attention: Data Protection Officer
1751, rue Richardson, Suite 1.050
Montréal (Québec) H3K 1G6
A User who seeks to exercise his/her data protection rights referred to in Section 12, in respect of Personal Information stored or processed by Workleap on behalf of an Instructor must direct his/her query to such Instructor, as being the data controller. If Workleap receives such User’s request to exercise his/her data protection rights referred to in Section 12 (including for access to or correction of Personal Information), Workleap shall redirect the User to the Instructor and, upon request from the Instructor, shall assist the Instructor responding to such request, if applicable.
Our Data Protection Officer will attempt to respond to your request within the legally applicable timeframe, and in any case no later than 30 days after receipt of such request. We will advise you in writing of our response to your request. Should we refuse to grant your request, we will inform you of the legal reason of our refusal, and we will apprise you of remedies available to you and of the time limit for exercising them.
Should you be unsatisfied with the outcome of your request, you may lodge a complaint with Workleap’s supervisory authority, the Commission d’accès à l’information.
Should you experience any problem or wish to obtain additional information, please contact us by e-mail at email@example.com.
SCHEDULE 1: Workleap LMS Sub-Processors
|Sub-processor||Type of processing||Country||Transfer Mechanism|
|Amazon Web Services, Inc.||Cloud Provider||United States of America and Canada||Standard Contractual Clauses|
|Microsoft, Inc.||Cloud Provider||United States of America and Canada||Standard Contractual Clauses|
|Intercom R & D Unlimited Company||Product discovery and re-engagement tool||United States of America||Standard Contractual Clauses|
|Slack Technologies, LLC||Internal communications||United States of America||Standard Contractual Clauses|
|Atlassian, Inc.||Team collaboration tool||United States of America||Standard Contractual Clauses|
|Google LLC||Cloud provider (email)||United States of America||Standard Contractual Clauses|
|Heroku, Inc.||Application hosting service||United States of America||Standard Contractual Clauses|
|Render Services, Inc.||Cloud provider (database)||United States of America||Standard Contractual Clauses|
|Hubspot, Inc.||Customer Relationship Manager solution||United States of America||Standard Contractual Clauses|