The Institute of Metacognitive Programming

PRIVACY POLICY

At INSTITUTE OF METACOGNITIVE PROGRAMMING INC., (“IMCP”) we are committed to maintaining the accuracy, confidentiality and security of your personal information.

This Privacy Policy describes the personal information that IMCP may collect from or about you, a person who interacts with IMCP on our website or through our coaching services or otherwise. It also describes how we use, and to whom we disclose, that information. It is IMCP’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation or a person’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all persons or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

This Privacy Policy was last updated April 23, 2024.

Personal Information

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual such as your name and e-mail address, but is not aggregated information that cannot be associated with a specific person. We do not knowingly collect personal information from persons under the age of 13 years.

How Personal Information is Collected

As a general rule, IMCP collects personal information directly from you. In circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions).

From time to time, we may use the services of third parties in our activities and operations and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise.  Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Form of Personal Information Collected

We may collect information related to your visit to our website or use of our service including the through your participation in our services or through the internet protocol (“IP”) address and domain used to access our services and website. We may also be provided with the type and version of your browser, the website, portal or platform from which you came to access our services, the pages at which you entered and exited, affiliate log-in credentials, any website page that is viewed by that IP address and what country you are from. If you use a mobile device with location services enabled, we may collect and process information about your actual location through GPS signals, nearby Wi-Fi access points or cell towers. We use this information to monitor our services as well as website’s performance (such as number of visits, average time spent, page views) and for our business purposes.

In addition, we collect the personal information that you submit to us, such as your name, username, email address and any other contact or other information that you choose to provide by using the “contact us” portion of the website.

In the course of providing personalized services to you we may collect personal information you provide to us such as your biographical or biological details (name, sex, age, race), nationality, religion, marital status, education, medical or criminal history, financial information, identifying numbers, for example, Social Insurance Numbers and birthdate, contact details (personal address, phone number, social media handles etc.), political affiliation, career aspirations and employment history and such other personal opinions and views amongst other information. We do not knowingly collect, nor do we seek to collect, personal health information but may provide generalized health information which will not, in any manner, constitute medical advice.

Where you request information from us, we may use the e-mail address that you provide to send you information about offers on our services that we believe may be of interest to you. If you have asked us to put you on an e-mail mailing list to provide you with certain information on a regular basis, or if we send you information about our offers on products and services by e-mail, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each e-mail and on our website).

Use of Cookies

When you visit our website or log in to the service, we place a “cookie” during the sign in process on the hard drive of your computer or device to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser and that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your login status and preferences. The cookie allows us to track your visits to affiliate websites so that we can better understand your use of our service and so that we can customize and tailor the service to better meet your needs.

Most web browsers’ default setting is to accept cookies. However, web browsers enable you to change this setting to have your web browser either notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie or automatically prevent the placing of a cookie on your hard drive. If cookies are not accepted, you may not be able to access certain pages on the website. IMCP partners may use other tracking technology such as a web beacons, software installations or otherwise which may also not function if cookies or the other third-party software technology is not accepted.

IMCP may allow third-party companies to serve ads or collect certain anonymous information when you visit our website or use our services. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other websites in order to provide advertisements likely to be of greater interest to you. These companies typically use a cookie or third-party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit networkadvertising.org.

Third Party Website Links

Our website, social media spaces or email digests may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only. We cannot assume any responsibility for the accuracy or form of the content, privacy practices, policies or actions of the third parties that operate these websites, platforms or portals which you access our services. IMCP is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these platforms, portals or websites before providing them with personal information.

Purposes of Collecting Personal Information

IMCP collects personal information to enable us to undertake, manage and maintain our activities, improve our coaching and advisory services and operations, including:

• to establish, maintain and manage our relationship with you so that we may provide you with the products and services that have been requested;
• to be able to review the products and services that we provide to you so that we may understand your requirements for the targeted products and services and so that we and our partners may work to improve the products and services including by providing patches, fixes, bug corrections and other forms of updates and improvements;
• for marketing and promotional purposes, including remarketing to our users about products or events that we think may be of interest to them as well as for highlighting case studies, problem-solving methods, and outcomes of the services ;
• to conduct research and statistical purposes and provide reporting for internal and external clients;
• to be able to comply with your requests;
• to protect us against error, breach, fraud, theft and damage to our property;
• to enable us to comply with all applicable laws or regulatory requirements; and
• any other reasonable purpose to which you consent.

Use of Your Personal Information

We may use and disclose your personal information:

• for the purposes described in this Privacy Policy; or
• for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

Disclosure of Your Personal Information

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist us in the provision of services to you including, but not limited to, provisioning of product details, website and other platform hosting/distribution and payment processing; and third parties whose services we use to conduct our activities and operations.

Further, your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, summonses, or court orders;
• to protect the rights and property of IMCP;
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• if IMCP is acquired by or merged with another company. IMCP may disclose your information to satisfy any reasonable diligence required to effect a merger or acquisition without further notice;
• where the personal information is publicly available; or
• with your consent.

You acknowledge that providing your information to us that you are disclosing this information for the purposes of public consumption and waive any privacy rights you may have in that information.

Consent

We collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. When you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we endeavour to advise you of that purpose before such use or disclosure.

As described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Withdrawing Consent

You may withdraw or alter your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Protection of Personal Information

IMCP endeavours to maintain physical, organizational, technical and procedural safeguards that are commercially appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss or theft and unauthorized access, copying, use, modification or disclosure.

The information IMCP collects about you may be stored on servers outside your home country. If you are visiting our websites from a country other than Canada or your home country, please note that countries in which we may be hosting servers may not have the same data protection laws as your country or jurisdiction and that your personal information may be subject to access by law enforcement authorities in the jurisdiction in which your personal information is stored. By providing your personal information to IMCP, you are consenting to the use of your personal information for the uses described in this Privacy Policy and the potential transfer of your personal information to a country outside your home country.

By using our service you are consenting to the Terms of Service and this Privacy Policy. You also consent and acknowledge that no data transmission over the Internet is completely secure. We cannot guarantee or warrant the security of any information you provide to us and you transmit such information to us at your own risk.

The security of your personal information is important to us. Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Access to Your Personal Information

Your account contains information provided by you on registration such as username, email and other identifying information. Please log in to your account to edit, modify or remove this information.

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with, the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Questions about this Policy

If you have any questions or concerns about this Privacy Policy or how we manage your personal information, please contact our Privacy Officer at the e-mail provided below. We endeavour to answer your questions in a timely manner and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in the appropriate Canadian provincial or federal jurisdiction.

Our Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

INSTITUTE OF METACOGNITIVE PROGRAMMING INC.

E-mail:  documents@imcp.org

Revisions to this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We post this Privacy Policy on our website and we encourage you to refer back to it on a regular basis.

Interpretation of this Privacy Policy

Any interpretation in an action, arbitration or otherwise associated with this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy does not create or confer upon any person any rights, or impose upon IMCP any obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws. Any action brought in relation to this policy, directly or indirectly, shall attorn to the courts of the Toronto region and be interpreted in accordance with the laws and jurisdiction of the Province of Ontario.