Type of website: Social Enterprise

Effective date: 3rd day of May, 2022

 

https://www.ioi.live/  (the "Site") is owned and operated by Heidi Philip Consulting Inc.

Heidi Philip Consulting Inc. is the data controller and can be contacted at:

 

hello@ioi.live 

+1.416.558.1378

101 Moore Avenue, Toronto, ON, Canad M4T 1V7

 

Purpose

We at the InsideOut Intelligence (“IOI” "ioi", “we”, or “us”) know you care about how your personal information is used and shared, and we take your privacy seriously. This Privacy Policy outlines how we collect, use, and share personal information. Please read it carefully, because by using or accessing the Services in any manner, you accept and consent to the practices and policies described below.

 

The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the following:

1. The personal data we will collect;

2. Use of collected data;

3. Who has access to the data collected;

4. The rights of Site users; and

5. The Site's cookie policy.

 

Remember that your interaction with and use of IOI’s Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

 

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. As described further below, a Publisher’s EULA governs the use of Personal Information it collects from an End User on the Publisher’s subdomain on the Services. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain Publisher Newsletters, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

 

GDPR

For users in the European Union, we adhere to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

 

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

 

Consent

By using our Site users agree that they consent to:

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The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing we completed before you withdrew your consent unlawful. You can withdraw your consent by contacting the organization directly and requesting the removal of your personal data.

 

Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

 

We rely on the following legal bases to collect and process the personal data of users in the EU:

 

1. Users have provided their consent to the processing of their data for one or more specific purposes;

2. Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the personal data necessary to perform a contract the consequences are as follows: Users who don't provide the necessary personal data cannot register for the IOI programs and courses.;

3. Processing of user personal data is necessary for us to comply with a legal obligation. If a user does not provide the personal data necessary for us to perform a legal obligation the consequences are as follows: Users who don't provide the necessary personal data cannot register for the IOI programs and courses; and

4. Processing of user personal data is necessary for a task carried out in the public interest or in the exercise of our official authority.

 

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first. We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect, without limitation, Personal Information such as your name, email address, and phone number. Certain information may be required to register with us or to take advantage of some of our features. We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our Services.

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If you do not want to receive communications from us, please indicate your preference by emailing us at hello@ioi.live or by following the opt-out instructions contained in such emails.

 

Data Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.

 

Also, if you click on a link to a third-party website or service, such third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

 

Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:

 

1. First and last name;

2. Age;

3. Date of birth;

4. Gender;

5. Email address;

6. Phone number;

7. Address; and

8. Payment information.

 

This data may be collected using the following methods:

 

1. Creating an account; and

2. Paying for the courses.

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How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

 

The data we collect automatically is used for the following purposes:

 

1. Statistics;

2. Social Media metrics;

3. Improving Services; and

4. Digital Marketing metrics.

 

The data we collect when the user performs certain functions may be used for the following purposes:

 

1. Communication;

2. Confirming legitimacy of identity;

3. Customization of features; and

4. Statistics and metrics of programs.

 

Who We Share Personal Data With

 

Employees & Contractors

We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

 

Our Service Providers:

We employ other companies and people to perform tasks on our behalf and need to share your Personal Information with them to provide products or services to you; for example, we may use a Third Party Payment Processor to receive and process your credit card transactions for us, such as Stripe. Any payment card information you use to make a purchase on the Services is collected and processed directly by our payment processor, Stripe, and we never physically receive or store your full payment card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI- DSS) and using industry-standard security. Stripe may use your Payment Information in accordance with its own Privacy Policy here.

 

Publishers

Publishers are granted access to certain information about End Users who subscribe to such Publisher’s Newsletters. IOI does prohibit Publishers from collecting or using any information beyond what IOI itself collects and uses pursuant to this Privacy Policy, but this does not mean we are responsible for reviewing or verifying the accuracy of any Publisher’s data collection or use policies. Publishers are solely responsible for complying with any laws and regulations that apply to End Users’ information, including without limitation the posting of any EULA on their subdomain on the Services. IOI is not liable for Publishers’ relationships with End Users. We encourage you to review Publishers’ individual privacy policies for more information regarding their use of and access to your Personal Information. We have no control over the policies and practices of third-party websites or businesses (or providers of Publisher Newsletters) as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

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Other Disclosures

We may partner, collaborate or co-create with third-party organizations and individuals (“entities”) who may have the ability to import their existing mailing lists to IOI, meaning they may share your email address with us. These entities represent to us that they have your permission to use your email address on our platform. If you believe your information was provided to IOI wrongfully, please email us at hello@ioi.live or, if applicable, use our CCPA processes to request the removal of that information.

 

Note also that third-party entities may have their own privacy policies and practices around their use of your information, which we encourage you to review and understand.

 

We will not sell or share your data with other third parties, except in the following cases:

 

1. If the law requires it;

2. If it is required for any legal proceeding;

3. To prove or protect our legal rights or protect the rights, property, or safety of IOI, our employees, our users, or others.; 

4. To buyers or potential buyers of this company in the event that we seek to sell the company.

 

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

 

How Long We Store Personal Data

User data will be stored until the purpose the data was collected for has been achieved. You will be notified if your data is kept for longer than this period.

 

How We Protect Your Personal Data

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

 

We endeavour to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, failure of the Services, or other factors may compromise the security of user information at any time.

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While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

 

Information Collected From Other Websites and Do Not Track Policy

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. 

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Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

 

Will IOI Share Any of the Personal Information it Receives?

We may share your Personal Information with third parties as described below: Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual. Affiliates: We may disclose your Personal Information to our subsidiaries and/or corporate affiliates for use consistent with this Privacy Policy.

 

Is Personal Information about me secure?

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavour to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, failure of the Services, or other factors may compromise the security of user information at any time.

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Your Rights as a User

Under the GDPR, you have the following rights:

1. Right to be informed;

2. Right of access;

3. Right to rectification;

4. Right to erasure;

5. Right to restrict processing;

6. Right to data portability; and

7. Right to object.

 

Children

The minimum age to use our website is 13 years of age. We collect the personal data of children under 16 years of age. We only collect the personal data of children under 16 years of age with the express consent of their parents or guardians. This consent is collected as follows:

1. Parental or Guardian Consent for children under the age of 16.

 

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data, and to whom we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer here:

 

Asma Kenshil

hello@ioi.live

+1.416.521.5105

101 Moore Avenue Toronto ON, Canada M4T 1V7

 

What Personal Information can I access?

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us: name and password email address user profile information, including images you may have uploaded to the site. The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at hello@ioi.live.

 

User Profiles and Submissions:

If your user profile allows it, you may choose to populate certain user profile information, including, without limitation, your name, location, and any image content. Any user profile information uploaded to the Services may be displayed to other users to facilitate user interaction within the Services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any Content you upload to your public user profile, along with any Personal Information or Content that you voluntarily disclose online in a manner other users can view (on discussion boards, in chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your username may also be displayed to other users if and when you post comments or upload images or videos through the Services and other users can contact you through comments.

 

How to Opt-Out of Data Collection, Use, or Disclosure

In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:

 

1. You can opt out of our marketing emails. You can opt out by clicking "unsubscribe" at the bottom of any marketing email.

 

Cookie Policy

A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

 

We use the following types of cookies on our Site:

1. Functional cookies

Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;

2. Analytical cookies

Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example, data on the content you access, how long you stay on our Site, etc;

3. Targeting cookies

Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalize the information you see on our Site for you; and

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4. Third-Party Cookies

Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:

1. Online payments.

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Modifications

We are constantly working to improve our Services, so we may need to change this Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we will alert you to changes by placing a notice on the Services, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

 

Business Transfers

We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
 

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

 

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us at hello@ioi.live. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

 

Complaints

If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. 

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Contact Information

If you have any questions, concerns or complaints, you can contact our privacy officer, Asma Kenshil, at:

 

hello@ioi.live 

+1.416.521.5105

101 Moore Avenue Toronto ON, Canada M4T 1V7