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LITTLE KITCHEN ACADEMY
PRIVACY POLICY

Little Kitchen Academy Ltd. and its corporate affiliates (“LKA”, “we”, “us”, “our”) respect and uphold individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services to you. Based on British Columbia’s Personal Information Protection Act (“PIPA”) to which we are subject, we have developed this privacy policy (the “Policy”) to explain our practices for processing our students’ and parents’ (collectively, “you” or “your”) personal information. This Policy does not apply to our employees’ personal information or any anonymized information.

This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose, and otherwise process (collectively, “process”), as well as how you may correct, update, and access, your personal information that you provide as a user of: (a) the website operated at https://littlekitchenacademy.com/, and other locations from time to time (the “Website”); (b) any front-end software we provide you that interacts or interfaces with the Website (the “Software”), excluding third party software that may interact with the Website or the Services as defined below; and (c) the services we provide through the Website, the Software, and/or the activities and classes offered at any of our locations (“Self-Improvement/Instructional Cooking Services”, and together with (a) and (b), the “Services”).

Our Website and Software may contain links or direct you to other websites, software, service providers, or Internet resources (the “Other Providers”), which are provided solely for your convenience, benefit, and information. When you click on one of those links, you are contacting another website, software, service provider, or Internet resource. We are not responsible or liable for, nor do we have control over, those Other Providers or how they process your personal information.  We encourage you to read the privacy policies of those Other Providers to learn how they process your personal information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY.  By using our Website, Software, or Services, or by otherwise choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected.  If you are located or residing outside of Canada, please be aware that our Website, Software, and Services are intended for and directed to users in British Columbia, Canada, and the privacy laws and principles in British Columbia, Canada may differ and not offer the same level of protection as those in your location or residing country/region.  Through your continued use of our Website, Software, or Services, you are transferring your personal information to Canada and you expressly consent to that transfer and we will use this consent as the legal basis for such data transfer, unless otherwise stated in this Policy.

MINOR CHILDREN. For greater clarity, this Policy applies to any personal information we collect or receive from you, including the personal information of minor children. Under PIPA, a minor’s guardian may (a) give or refuse consent to the collection, use, or disclosure of personal information; (b) exercise access to personal information rights; or (c) exercise correction of personal information rights, in each case if the minor child is incapable of exercising those rights. We encourage you and, if applicable, your minor child, if they are capable, to read this Policy thoroughly before providing us with any personal information and before using any of the Services. If you are exercising a minor child’s rights in accordance with (a), (b) or (c), any reference in this Policy to “you” or “your” personal information should be read and understood as including the minor child’s personal information, as well as your personal information.

By providing us with any personal information or using any of the Services, you are signifying that you agree with all of the terms of this Policy, so please do not do so if you disagree with any part of this Policy.

  1. Personal Information

For the purposes of this Policy, “personal information” means any identifiable information about an individual, including but not limited to an individual’s name, home address, telephone number, social insurance number, gender, income, and family status, except any other information otherwise exempted by PIPA. For example, personal information does not include any business contact information that is processed solely to communicate with that person about his or her employment or profession.

When you use our Website, Software, or Services, we may collect the following personal information from you:

  • Demographic information such as gender, age, marital status, and location of residence (city/province/country);
  • Contact information such as name, email address, mailing address, and phone number;
  • Billing information such as credit card number and billing address;
  • Unique identifiers such as username, account number, and password;
  • Professional information such as name of employer, occupation, location of occupation, and insurance; and
  • Your image, likeness, or other personal attributes via photographs or video recordings (for more information, see our Consent, Release and Waiver located at HERE

Your personal information may be collected when:

  • You register for an account with us;
  • You connect with us through social media;
  • You participate in Self-Improvement/Instructional Cooking Services;
  • We collect cookies and other tracking information through your use of our Website;
  • We collect data from third parties or publicly-available sources; and
  • We utilize and operate security systems, including video and other surveillance systems.

We only collect personal information that we need.  We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.

Collection from Third Parties

We do not knowingly collect your personal information from a third party unless you consent to such collection or we are otherwise exempted, required, or permitted by PIPA to do so.  For example, we may collect your personal information from organization(s) that you previously provided with consent to collect that information, or public sources in which your personal information is publicly available.

If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected.

Cookies and Log Files

To ensure our Website, Software, and Services are optimized for your use and for future communications between you and us, we may save your user data in the form of cookies or log files and use such cookies or log files to collect standard Internet log information about how and when you use our Website, Software, or Services. This information may include, but may not be limited to, your IP address and location data, weblogs, time zone, date, your language preferences, browsers used, web addressees visited, other communication data, searches conducted, and pages visited.  You can manage your cookie preferences, but please note that if you refuse to allow cookies, you may not be able to use certain features of our Website, Software or Services.

  1. Purpose for Which Personal Information is Processed

We may process your personal information for the following purposes (the “Purposes”, and each, a “Purpose”):

  • To verify and authenticate your identity;
  • To process registrations;
  • To provide you with Self-Improvement/Instructional Cooking Services, including information regarding activities, performance, behaviour, health, and personal matters as required in order to provide the best possible environment for learning;
  • To connect with us through social media;
  • To display student activities related to the Self-Improvement/Instructional Cooking Services on our Website, social media accounts, or in other promotional materials or internal publications (for more information, see our Consent, Release and Waiver located HERE
  • To investigate breaches of law and/or complaints of breaches of our policies (including the Code of Conduct);
  • To ensure that the Website, Software and Services are optimized for your use and benefit;
  • To operate, maintain, and provide to you with the Services, as well as the features and functionality of the Website and Software;
  • To communicate with you to provide you with the Services, contacts, materials, updates on our activities, and/or recommendations for your needs as identified by you through phone, email, or the Website;
  • To carry out our obligations arising from any contracts entered into between you and us;
  • To comply with internal policies and procedures and other legal, accounting, or security requirements; and
  • To share your personal information with our employees, contractors, consultants, and other third party service providers such as web hosting providers, advertising agencies, payment processors, or customer service agencies (“Third Party Processors”) who require this information to assist us with establishing, maintaining, and managing our relationship with you and optimizing and providing the Website, Software, and Services for your use and benefit.

We will only process your personal information for the Purpose(s) for which we intend to process such information.  Otherwise, we will not process your personal information without your consent.

  1. Disclosure of Your Personal Information

We may disclose your personal information for the Purposes as described in this Policy in the following ways:

  • To our employees or contractors;
  • To other LKA locations (for example, if a student moves to another market or wants to attend another LKA location, the enrolling location may request student records to facilitate ongoing education);
  • To our branding and marketing agencies, which assist us with formatting content displaying student activities related to the Self-Improvement/Instructional Cooking Services for our Website, social media accounts, or in other promotional materials or internal publications (for more information, see our Consent, Release and Waiver located HERE);
  • To our service providers, such as payment processors; and
  • To law enforcement, government or regulatory bodies, or other lawful authorities.

Your personal information that we collect may be processed in the United States or elsewhere outside of Canada. As a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the USA Patriot Act, the USA Freedom Act and other applicable laws of the United States or elsewhere.

We do not sell, lease, or trade your information to other parties.

  1. Legal Basis for Processing Your Personal Information

Consent

We will process your personal information only with your knowledge and consent, except where exempted, required, or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested.  Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed. By using our Website, Software, or Services, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected.  When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Website, Software, or Services or otherwise provide any personal information to us.

You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information, subject to legal or contractual restrictions and reasonable notice, by: (i) changing your privacy preferences through the Website or Software; (ii) deleting your account with the Website or Software and stopping use of the Website or Software; (iii) opting out of the use of your personal information such as unsubscribing to any newsletter or mailing list subscription that we provide through the Website or Software; or (iv) submitting a written request to our Privacy Officer specifying how you wish to withdraw or change your consent. However, if you withdraw or change your consent, we may not be able to provide you with the Services through the Website or Software.

  1. Security of Personal Information

The security of your personal information is important to us. We follow and employ generally accepted industry standards as appropriate to the sensitivity of your personal information that you submit, both during transmission and once we receive it. We take physical, administrative, contractual, and technological safeguards to protect personal information, and insist that our service providers do the same.  For example, we secure file cabinets under lock and key, provide ongoing training to our employees regarding protecting personal information, and ensure appropriate password and time-out functions are enabled to prevent unauthorized access to our networks. We insist that our personnel and those of our providers to only access and use personal information on a “need to know” basis to properly perform those duties, and even then only to the strict extent necessary to perform them.

However, no method of transmission over the Internet, or method of electronic storage, is completely secure; as such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

  1. Requests for Access to and Correction of Personal Information

You have the right to access, and/or request the correction of errors or omissions in, your personal information. These rights are in respect of:

  • Your personal information under our custody or control;
  • How your personal information may be or has been used by us; and
  • The names of any individuals and organizations to which your personal information has been disclosed.

Our Privacy Officer will assist you with such requests. We will respond to requests within the time allowed by PIPA and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.

In certain exceptional circumstances, we may not be able to provide access to certain personal information it holds about an individual. These circumstances include where evaluations are supplied in confidence by an instructor about a student with the mutual understanding that the evaluation will be confidential.

If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.

  1. CASL Policy

We are committed to compliance with Canada’s Anti-Spam Legislation(“CASL”). Any electronic communication we send to outside parties is protected by a range of business procedures, processes, and policies to ensure that such communication is made in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (each, a “CEM”) we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.

OurCEMs contain the following requirements prescribed under CASL, which will usually be in the footer of the CEM. We will:

  • Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
  • Provide you with our contact information; and
  • Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).

If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days.  If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated below.

  1. Retention of Your Personal Information

We keep your information only for as long as we need it for legitimate business purposes and compliance with legal requirements. Personal information used to decide on a matter that directly affects an individual will be kept for at least one year.We ensure that our retention standards meet these parameters by destroying or erasing your information once we no longer need your information, or once the required retention period passes. If we do not destroy or erase your information, we will remove any personally identifiable information so that it becomes anonymous.

  1. Updates or Changes to Privacy Policy

We may update this Policy to reflect changes to our information practices from time to time. If we make any material changes we will either (a) notify you by email (sent to the e-mail address listed in your account); or (b) provide a notice on the Website or otherwise through the Services before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that the privacy policy is posted or on the date as specified in the notification.

You will find the date of the latest update at the end of this Policy. We recommend that you print a copy of this Policy for your reference. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes.  Your continued use of the Services signifies your acceptance of any changes to this Policy.

  1. Contact Information for Privacy Officer

You can direct any questions or concerns regarding our compliance with this Policy and our processing of your personal information to our Privacy Officer:

Attention: Brian Curin, Privacy Officer

Address: 3744 West 12thAvenue, Vancouver, B.C.
Phone: 604.928.0629
Email: admin@LittleKitchenAcademy.com

If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under PIPA.  Our Privacy Officer will provide you with the contact information to do so if requested. We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.

  1. Changes to Privacy Policy

Privacy laws continue to evolve and, as a result, we may change this Policy from time to time at our full discretion without any prior notice or liability to you or any other person. The processing of your personal information by us will be governed by the version of this Policy in effect at that time.

End of Privacy Policy(Last Updated: September 18, 2019).