Privacy Policy

Last Updated: February 24th, 2021 

CultureWorks Inc. (“CW,” “we,” “us,” or “our”) provides users with the ability to investigate the process of becoming a student at our language school or certain other schools we are affiliated with around the world, including information respecting visa applications and program information. We also provide the ability to apply for admission to certain programs of such institutions through our recruitment partners. 

To do this, CultureWorks collects your personal data. This Privacy Policy sets out the manner in which CultureWorks collects, uses, discloses, and otherwise manages personal data. 

Periodically we will make updates to our policy and your continued use of CultureWork’s services and/or website after this date will be subject to our updated Privacy Policy. 

General 

In this privacy policy, we describe: 

  • the information that we collect and process about you (that you provide directly to us or is provided to us by third parties such as our recruitment partners). 
  • the purposes for which we collect and process information about you; and 

In this Policy, the term “personal data” or “personal information” means personal data or data that relates to an identified or identifiable person. 

We recommend that you read this Policy carefully in order to understand what CultureWorks Inc. and any affiliates and/or subsidiaries does with your personal data. Your use of our Website and Services and any dispute over privacy, is subject to this Policy and any of our applicable Terms and Conditions for use of our Services, including their applicable limitations on damages and the resolution of disputes. Our Terms and Conditions for our Services are incorporated by reference to this Policy. By visiting our Website, you are consenting to the practices described in this Policy. 

What We Collect and How 

How does CultureWorks collect my personal data? 

We collect personal data directly from you, about you from third parties such as our marketing affiliates and service providers used to verify your identity and prevent fraudulent activity and 

automatically as you use our Website and the Services. At this time, use of our Services is only available to users who register on our customer relationship management system “CRM” for our Services. 

We, and our third party service providers, automatically collect the following information about your use of our Website and our online Services through cookies, web beacons, log files and other technologies (subject to your consent where required by applicable law): your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Website or use our Services, your activities on our Website, and the referring URL or the webpage that led you to our Website. Please see the section “Our Use of Cookies and other Tracking Mechanisms” below for more information. What personal data does CultureWorks collect? 

The types of personal data we collect about you depends on your particular interaction with our Website and our Services, and generally includes, where permitted by applicable law, but generally falls under the following headings; 

Name, home address, email and or social media address, phone number, billing or mailing address, IP address, date of birth, national identification numbers and documents that may include your photograph and/or government identifier. Educational exam results, Professional credentials and skills, work history, evaluations, references, interviews, certifications, disciplinary matters and other information of the type included on a resume, curriculum vitae or cover letter. Any other information that you choose to provide to us (e.g., when you send us an email/otherwise contact us). 

When We Collect Your Information and How We Use It 

CultureWorks collects your personal data whenever you do any of the following and uses it as described: 

Create an Account on our inquiry form: To commence communication with CultureWorks you are required to create an account and provide your email address. Your login information is used to create your account, and otherwise provide and administer the service you requested. 

You do not have to create an account to visit and browse certain features of our Website, such as to browse programs we offer or learn more about our partner schools, read other content portions of the Website, or determine your eligibility for certain programs. If you choose to use our Website to discover programs you are eligible to apply for, we collect personal data such as your nationality, country of education, highest education, grading scheme, grade average, English/French exam score(s) and the disciplines or programs that you are interested in pursuing. CultureWorks uses this information to access programs and schools to which you are eligible to apply. 

Create a Student Profile and/or Apply to an Educational Program by completing our Application form: In order to apply to an educational program, you (or the recruitment partner acting as your legal representative) are required to create a student profile on our CRM. The personal data we collect in your student profile helps us evaluate your English competency and match you with schools and programs that fit your preferences and qualifications. This information may also be required by the school for the purposes of processing your application. This information may include your first and last name, email address, gender, date of birth, home and mailing address, passport details, marital status, emergency contact information, English test scores, educational preferences (such as preferred study destination and educational fields of interest), education history, volunteer experience, and other educational information. 

Provide Information to Third Parties With Whom We Work: We may obtain personal data about you directly or through your legal representative, or a recruitment partner(s) who you are working with and who are using our services to process your application to schools. Occasionally, CultureWorks will obtain information about you from third parties, third-party. Third-party providers are responsible for obtaining consent to provide personal data to us. 

Payment Processing and transaction tracking: CultureWorks uses, with your consent, third party PCI certified payment service providers including but not limited to Western Union, PaymyTuition, Moneris, or SnapPay. When you directly make a payment using these payment service providers, you are subject to their privacy policies. They are independent of CultureWorks and CultureWorks is not responsible for their privacy practices. 

Sign Up for Marketing Email and Other Communications: We may offer you the ability to sign up to receive CultureWorks marketing and promotional communications through the Website, on third party websites (including through social media sites), or educational events and information sessions. In these circumstances, we collect certain personal data (such as first and last name, email address, social media identifier, and or mobile phone number) which we use to send you communications containing CultureWorks updates, tips, and other content that may be of interest to you. You can opt out of receiving promotional email from us by following the “opt-out” or “unsubscribe” instructions provided in your email or text message, or by contacting us as set out below. Please note that you may continue to receive messages from us regarding your application or other transactional and account-related electronic messages from us. 

Apply to Become an CultureWorks Recruitment Partner: In connection with applying to become a potential recruitment partner with CultureWorks, you may provide us with certain personal data such as your first name, last name, address, email address, personal data about your education and employment background and banking data. We use this information for the purpose of processing and responding to your application to become an CultureWorks Recruitment Partner and for paying you as needed using third party payment processors. 

You are responsible for providing accurate and up-to-date information. 

When Do We Share Your Information 

We share your personal data with third parties, including service providers, regulated institutions (e.g., financial institutions), affiliated entities, and business partners, these entities include. 

Schools, Partners, Service Providers, Related Parties, Legal Entities 

How and Why, We Share Your Information 

If you do not want us to use your personal data for us to market to you, and/or to pass on to third parties for marketing purposes, please contact us through the various communication channels available, as listed under the Section titled “Contact Us, Questions, Updating Your Info, Opting Out” below. You will also be able to unsubscribe from any marketing emails sent to you by CultureWorks using a link provided in such emails. We do not sell your personal data. 

Where We Store Your Data 

All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our domains, either CRM or website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 

CultureWorks uses predominately hosted servers some are located in Canada or the USA, however some of our services are stored on servers outside of Canada in addition many of our service providers are also located outside of Canada. While we use appropriate safeguards to keep your information secure, the laws in other places may differ from those in Canada and authorities in those jurisdictions may access your information in accordance with their local laws and we cannot be responsible for the security of such hosted services. 

Safeguards 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. 

Your Rights 

You have the following rights: 

  • Access 
  • Correction (Right to rectification) 
  • The right to withdraw your consent/be forgotten 
  • The right to report or complain 

You may access, update and correct inaccuracies in your personal data in our custody or control at any time, subject to limited exceptions prescribed by law. Simply log into your account, go to your account profile, and make the necessary changes. 

You can also request access, corrections or updates to other personal data in our records by contacting us as set out below. We may request certain personal data for the purposes of verifying the identity of the individual seeking access to their personal data records. 

You may request your data be withdrawn (forgotten); this type of request can be performed assuming CultureWorks is in a legal position to fulfill such a request. You must not have an active study application where financial or billing records are or may be in process should an application to a third-party service be engaged. Should CultureWorks be able to comply with your request, only the personal data you provided will be forgotten. Non-personal data (“Metadata”) will be maintained regardless. 

Should you wish to lodge a concern or complaint to CultureWorks, please contact us as set out below. We will respond to your concerns in a reasonable time, typically within 30 business days. 

Use of Cookies and Other Tracking Mechanisms 

We and our third-party service providers use cookies and other tracking mechanisms (including tracking technologies designed for mobile applications) to track information about your use of our Website and Services. We may combine this information with other personal data we collect from you (and our third-party service providers may do so on our behalf). 

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Website and Service. 

Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. We 

may use cookies to bring together information we collect about you. You can choose to have your device warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. If you turn cookies off, you won’t have access to many features that make your guest experience more efficient and some of our services will not function properly. Please see the last section of this Cookies Policy for more information about how to manage or disable browser cookies. 

We use several categories of cookies and each performs different functions. You can learn more about cookies and their functions generally by visiting an information website like allaboutcookies.org

There are four types of cookies: 

Strictly necessary cookies, Analytical/performance cookies, Functionality cookies, Targeting cookies 

The four types of cookies above will be either session cookies or persistent cookies. 

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website or Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Website or Services. 
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to remember your user information, preferences and activity, to enable us to provide our services to you when you next return to our Website or Services. We also use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information. 

HTML5 Storage. We may also store your user information and Website preferences locally within your web browser via HTML5. 

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website or Services to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website and Services usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. 

Changing or Disabling your Cookie Settings. Most web browsers automatically accept cookies, but if you prefer you can edit your browser options to block them in the future. The Help 

portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable their web browsers’ ability to accept cookies will be able to browse the Website; however, most site features will not function if you disable cookies and you will not be able to login to use our services. 

Disabling/Enabling Cookies Via Your Browser 

There are a number of ways for you to manage cookies and other tracking technologies. Through your browser settings, you can accept or decline cookies or set your browser to prompt you before accepting a cookie from the websites you visit. You should be aware that you may not be able to use all our interactive features if you set your browser to disable cookies entirely. 

If you use different computers in different locations, you will need to ensure that each browser is adjusted to suit your preferences. 

You can delete or disable any cookies that have been installed in the cookie folder of your browser. The various browsers provide different procedures to manage your settings. Click on any of the browser links below for instructions. 

  • Microsoft Windows Explorer 
  • Google Chrome 
  • Mozilla Firefox 
  • Apple Safari 

If you are not using any of the above-listed browsers, then you should select “cookies” in the “Help” function for information on where to find your cookie folder. 

You should also be aware that disabling cookies does not disable other types of analytics products which we may use to collect generic information about how you and other visitors use our website. 

Websites: Our Website may contain links to other websites that CultureWorks does not own or operate, including the websites of third-party partners. Also, links to our Website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no 

responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information. 

Third-Party Analytics 

CultureWorks uses the web analytics services from Google Analytics, to collect standard internet log information, we may add to this list of analytic providers from time to time and will not reissue our Privacy Policy each time we do. Tools such as these may use cookies to help us analyze how visitors use the Website. For example, with Google Analytics, the information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by a Google server. Google uses this information for the purpose of evaluating your use of the Website, compiling reports on Website activity for Website operators, and providing Website operators with other services relating to Website activity and internet usage. You can prevent the storage of data relating to your use of the Website and created via the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links: https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/topic/2919631

Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioral ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices

  • Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests. 
  • To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again. 

Data Retention 

CultureWorks will only retain your personal data while it is needed to fulfill the intended purpose for which it was collected or as otherwise permitted or required by law or contract (which may extend beyond the termination of our relationship with you). 

Typically, personal data is maintained during the time you are engaged in our programs or the institutional program you applied to, or for up to five years following our last contact with you. However, we may retain certain data indefinitely as necessary for: 

  • legitimate business purposes, such as auditing, account recovery; 
  • if required by applicable federal, state, provincial or other laws; 
  • to prevent fraud or future abuse, or 
  • by contract with a partner and/or institution. 

All retained personal data is treated in accordance with this Privacy Policy. 

If you request that your personal data be removed from our databases and/or systems, it may not be possible to completely delete all your personal data due to technological and legal constraints. However, we will take such steps as are reasonable to securely destroy the information or to ensure that the information is de-identified and/or anonymized as necessary. 

Should you request additional services from CultureWorks which are subject to this Privacy Policy, you will be authorizing the extension of the data collection and/or processing purpose as a result. 

Changes to Our Privacy Policy 

This Policy may change from time to time. Any changes in the future will be posted on our Website. 

We strongly encourage you to check back frequently to see any updates or changes to our Policy. 

Contact Us, Questions, Updating Your Info, Opting Out 

If you are an CultureWorks Services customer or service provider and would like to update your personal data, please log into your CRM account in order to update certain information or 

contact us through the contact information below. If you are not an CultureWorks Services customer or service provider but have provided us with personal data or if your personal data was provided to us by third parties, and you would like to update your personal data, you may contact us through the email address listed below. Please contact our 

Privacy Administrator if: 

  • You have any questions or comments about this Privacy Policy 
  • You wish to access, update, and/or correct inaccuracies in your personal data and are unable to do it yourself, or 
  • You otherwise have a question or complaint about the manner in which we or our service providers treat your personal data. 

You may contact our Privacy Administrator by email at PA@cultureworkstheschool.com