Effective from: April 5, 2018
Privacy at Sencia is governed by the Personal Information Protection and Electronics Document Act (PIPEDA) and our elective compliance with the EU General Data Protection Regulation.
This policy does not apply to any third-party products or services that clients may choose to integrate with our products services, such as add-ons, plugins, or software. Clients are responsible for reviewing the policies of third-party products are services.
Sencia provides several products through a Software-as-a-Service (SaaS) model, that is, our products are delivered through cloud-based centralized hosting and licensed on a subscription basis. The data we collect data is based on either a business need or as directed by our clients. We store and process information and content that our clients create, input, submit, post, upload, transmit, store, or display in the process of using our products. Such content includes any personal information or other sensitive information that a client chooses to include.
Our clients, and not Sencia, determine their own policies regarding storage, access, modification, deletion, sharing, and retention of information and content that may apply to an individual's use of the product. For example, a client may provide or remove access, manage permissions, transfer users, or control access to content. Please check with the client about the policies and settings that they have instituted with respect to information and content that you provide when using our products and services.
3.1 The Information We Collect
The information Sencia collects depends upon the products and services used, how they are used, and what individuals choose to provide. We process information when necessary to provide services requested by our clients under license, where we have obtained an individual's consent, or where we have a legitimate interest to do so. For example, we may have a legitimate interest to process information for security, testing, maintenance, and enhancement purposes of the products and services provided, or for analytics, research, and reporting purposes. Without the information, we cannot provide clients with the services requested or they may be limited in their use of the services. The types of data we collect directly from individuals may include name, address, telephone number, and email address.
A. Information Provided by Clients and Individuals
The majority of information we process is provided directly to us by clients and individuals associated with those clients through the use of our products.
Clients and their users may upload or input various types of content, including but not limited to: videos, images, courseware, text, design elements, group names, and file attachments. If you are using a Sencia product in connection with an account created by one of our clients (e.g., employer, organization, or an individual), we collect and process the content submitted on behalf of the client.
Sencia collects information provided to us via:
- Account and product registration and administration of accounts.
- Products and services used.
- Requests or questions submitted to us via telephone, forms, or email.
- Communications and dealings with Sencia.
- Participation in assessments, contests, or research.
- Uploads or posts to our products.
- Requests for customer support and technical assistance.
We do not store credit card information in our systems. Credit card transactions are processed by the client's chosen payment gateway (e.g. Moneris). These payment gateways are third-party merchants that are responsible for using secure encryption.
B. Information Automatically Collected
When individuals use our products and services that connect to the Internet, Sencia uses a variety of technologies, including cookies (see the Cookies section below) and similar tools, to assist in collecting certain information.
- Log Files
Our servers may automatically record certain information in server logs. These server logs may include information such as your web request, IP address, browser type and settings, referring / exit pages and URLs, metadata associated with uploaded content, domain names, landing pages, pages viewed, date and time stamp information, and other such information.
- Device Identifiers
We collect specific device information, including your MAC address and other unique device identifiers. We also collect information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your account and will use data associated with your device identifier to customize our services to your device and to analyze any device-related issues.
- Location Information
We process general information about the location of the device from which you are accessing our products (e.g. approximate geographic location inferred from an IP address).
C. Information Collected From Third-Party Integrations
Some of our clients choose to use third-party integrations through our products. Such providers may allow Sencia to have access to and store additional information about your interaction with those services and platforms as it relates to the use of our products.
3.2 Personal Information
When using our products, individuals may submit personally identifiable information as they participate in any interactive features of our products. This refers to information about a person that can be used to contact or identify that person, and information on a person's activities as conducted using our products. Another user (such as a system administrator) may create an account on behalf of another person and provide information about that person, including personal information.
A. Use of Personal Information
We may use personal information to provide our clients and their customers with products and services or for other purposes identified at the time of collection by our clients. Personal information should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date. We may also occasionally collect data from individuals who participate in assessments, contests, activities, or events we host.
Personal information may be used for the purposes listed below.
- To administer client use of our products.
- To bill for products and services.
- To respond to inquires, comments, and requests.
- To resolve support issues.
- To provide or offer software updates and product announcements.
- To improve our products, services, features, and content.
- To understand client and potential client requirements.
- To personalize client experience.
- To establish a sales contact.
- To interview and assess job applicants.
B. Who Has Access to Information?
Our clients, and not Sencia, determine who in their organization can access and see the personal information they collect. For example, a client may run provide reports that contain personal information and share those reports at their discretion. Please check with the client about their policies with respect to any information they collect about you.
System administrators, client designates, and Sencia support personnel may be able to:
- Access information from an individual's account.
- Access communications history, including file attachments, for individual accounts.
- Disclose, restrict, or access information provided by individuals, including content.
- Control how an account may be accessed or deleted.
- Access information from reports generated from our products.
Personal information may be transferred to third-parties who act for or on our behalf of Sencia or our clients for further processing as permitted by clients and in accordance with lawful processing, such as data storage, service providers, maintenance services, database management, web analytics, and payment processing. These third parties have access to personal information only for purposes of performing these tasks on our behalf. Personal information may also be transferred to a third-party in the event that Sencia a part of it and the client data connected with it is sold, assigned or transferred.
C. Sharing Information
Personal information is subject to the laws of the jurisdiction in which it is located. Personal information may be disclosed if required if lawfully requested by government authorities, court order, law, regulation, or if such disclosure is otherwise necessary for the support of a criminal investigation, or legal process. Personal information may also be disclosed if, based solely on our discretion, we consider there is a risk to the safety of the public or any person, to prevent or stop any activity we may consider to pose a risk of being illegal, unethical, inappropriate, or legally actionable.
Sencia will comply with and uphold the individual's rights to their own data. Individuals with personal data in our products have the rights to view and access their own personal information, request a copy of their personal information, and request that personal information is updated, erased, or restricted from processing, at any time. Client administrators may facilitate these requests from individuals within their organization. Accounts managed by a client administrator have control with regards to how account information is retained, suspended, and deleted.
Some of Sencia's products and services require individuals to register or create an account. When an account is created, our clients may require that certain fields be completed (some are required and some are optional), as well as choose a username and password or provide other personal information. In these situations, an individual is not required to provide the information, however, withholding any of the required information will make it impossible to gain access to functionality.
If you are an individual that would no longer like us to process your information, please contact the organization that collected your information so that they can process your request. Individuals may also contact us at the contact information below. We will respond to your request within 30 days.
3.4 Security and Confidentiality
Sencia is committed to ensuring that the confidentiality of personal information is protected and maintained. We will process personal data securely, apply and maintain appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing. We have adopted policies compliant with Canadian and European law in an effort to ensure effective levels of data protection relating to transfers of personal information outside of Canada (this is known as data transfer).
Personal information may be displayed on profile pages and elsewhere in our products according to the requirements established by our clients. We recommend that clients guard and restrict the anonymity of personal information and think carefully about what information they collect from their users.
3.5 Cookies and Technical Collection
Information obtained by technical means is necessary to monitor and analyze the behaviour of our products, conduct technical administration, review of the website use of our users, and to verify that our products meet the criteria required to process client requests via our products. Examples of this type of data are automatic recording performed by our servers for handling statistics. This information may include but is not limited to an individual's device IP address and browser type.
Information may also be transmitted via cookies. Cookies are small data packets that web pages insert into web browsers (e.g. Google Chrome) for record-keeping purposes. Every time an individual returns to the same URL, their device sends back the package of information. One common example of this is when a web browser saves username and password information for future logins. Individuals can change browser settings to stop accepting cookies or to prompt them before accepting a cookie from the websites. Consult the Help section of the browser for more information (e.g., Internet Explorer/Edge, Google Chrome, Mozilla Firefox, Safari).
If an individual does not accept cookies, they may not be able to use all the functionality of our products.
3.6 Links to External Websites
3.7 Policy Revisions
If you object to a revision, you may cease using the product or service. Continued use of our products and services shall constitute your acknowledgement and acceptance of such changes.
For questions about this policy, email us at sencia%23ca|datasecurity