Privacy policy

LAST AMENDED July 28, 2023.

PRIVACY POLICY

INTRODUCTION

Elementary Curriculum Digitizers Incorporated (the “Company”) respects your (“You” and “Your”) privacy. This Privacy Policy describes how Elementary Curriculum Digitizers Incorporated collects, uses, maintains, discloses, and protects Personal Information (defined below), as well as the rights and choices You have regarding Your Personal Information, including how You can access and update Your Personal Information. This Privacy Policy was last amended July 28, 2023. “Personal Information” is information that identifies You or could be combined by Elementary Curriculum Digitizers Incorporated or Elementary Curriculum Digitizers Incorporated’s services providers or affiliates with other information to identify You. By accessing or using Elementary Curriculum Digitizers Incorporated’s website located at clickmelearning.ca (the “Website”) or any content on or through the Website, You signify Your consent to the terms of this Privacy Policy and Your intent to be legally bound by them. If You do not agree with any terms of this Privacy Policy, please do not access or use the Website or any content on or through the Website, or otherwise submit any Personal Information to Elementary Curriculum Digitizers Incorporated.

TYPES OF PERSONAL INFORMATION COLLECTED

The Personal Information Elementary Curriculum Digitizers Incorporated collects about You will depend on the manner in which You access or use the Website or any content on or through the Website and may include:

▪ Your name, and contact information, such as Your town, province and country or full mailing address, or email address, or other similar information associated with You;

▪ Your location, time-zone setting, network information, device type, browser type and

version, browser plug-in types and version, operating system and platform, language,

standard web log data, and IP address used to connect Your computer to the Internet

or other similar identifier, or the equipment You use to access or use the Website and

usage details;

▪ Data on the pages, services, or content You access or use on or through the Website, including the amount of time You spend on certain pages, products or services You viewed or searched for, clickstreams to, through, and from the Website, page response times, downloads and download errors, page interactions, or methods used to browse away from the Website;

▪ Billing or account information, if applicable; and

▪ Any other Personal Information that You choose to submit to us.

The Website and any content provided on or through the Website is not directed to any person who is not the legal age of majority under applicable law.

Elementary Curriculum Digitizers Incorporated will not knowingly collect Personal Information from any person who is not the legal age of majority under applicable law. You, Parents and Guardians, having attained the legal age of majority under applicable law, may choose to share Personal Information about Your child(ren) with Elementary Curriculum Digitizers Incorporated.

PLEASE NOTE: Apps produced by Elementary Curriculum Digitizers invite You and Your child(ren) to use Your microphones with speech recognition software to assist You and Your child(ren) to access information on our apps. You may use some features without granting access to Your microphone. Audio provided by You and Your child(ren) is used solely for navigation purposes. Audio provided by You and Your child(ren) is not recorded, nor stored within our apps.

METHODS FOR COLLECTING PERSONAL INFORMATION

Elementary Curriculum Digitizers Incorporated takes steps to ensure that any Personal Information we collect about You is adequate for, relevant to, and not excessive for the uses of such Personal Information, as described by this Privacy Policy.

Information Provided to Elementary Curriculum Digitizers Incorporated by You

Personal Information Elementary Curriculum Digitizers Incorporated collects from You on or through the Website and as a result of Your access to or use of the Website or any content on or through the Website may include Personal Information You provide Elementary Curriculum Digitizers Incorporated directly, for example by:

▪ filling in forms, making search queries, or corresponding with Elementary Curriculum Digitizers Incorporated on or through the Website, or otherwise communicating with Elementary Curriculum Digitizers Incorporated by any means including by phone, email, or other electronic messaging; or

▪ if applicable or available through or on the Website: creating or registering for an account; subscribing, donating, or requesting information on a service or product; entering a promotion; or otherwise engaging with Elementary Curriculum Digitizers Incorporated through interaction points that might exist from time-to-time between You and Elementary Curriculum Digitizers Incorporated.

Information Collected by Elementary Curriculum Digitizers Incorporated Through Technological Means

Elementary Curriculum Digitizers Incorporated may also use cookies or other technological collection methods to collect information, some of which may be Personal Information, about:

▪ The device or equipment You use, including information about Your computer or mobile device, internet connection, IP address, operating system, and browser type; or

▪ Your browsing activities and patterns, including information about Your visits to the Website such as traffic data, location data, logs, and other similar communication data. This information helps Elementary Curriculum Digitizers Incorporated improve the Website and the content available on or through the Website and otherwise improve the services of Elementary Curriculum Digitizers Incorporated by:

▪ helping Elementary Curriculum Digitizers Incorporated understand audience sizes and usage patterns on the Website;

▪ allowing Elementary Curriculum Digitizers Incorporated to tailor the Website to Your preferences and interests; and recognizing You when You visit the Website multiple times.

The technologies used by Elementary Curriculum Digitizers Incorporated to automatically collect the information described above may include cookies, which are small files placed on the hard drive of Your computer. You can turn off cookies using Your internet browser but doing so may limit or remove certain parts of the Website, certain content on the Website, or the functionality of the Website.

Third-Party Features

The Website may include, integrate, or rely on links, plug-ins, services, social networks, content, or applications of third parties. Your access or use of such links, plug-ins, services, social networks, content, or applications may allow the third-party provider to collect or share information about You, some of which may be Personal Information. Elementary Curriculum Digitizers Incorporated does not control such third parties’ use of cookies or similar technologies.

▪ if You would like to know more about how these third parties use such technologies, You should contact the responsible provider directly. Elementary Curriculum Digitizers Incorporated does not accept any responsibility or liability for the privacy policies of any such third parties or their compliance or non-compliance with such privacy policies.

USING AND DISCLOSING PERSONAL INFORMATION

Use of Personal Information by Elementary Curriculum Digitizers Incorporated

Elementary Curriculum Digitizers Incorporated collects Personal Information to provide You with a secure, smooth, efficient, and customized experience through or on the Website or any content on the Website. Elementary Curriculum Digitizers Incorporated may use Your Personal Information to:

▪ provide You with content, services, or products on or though the Website;

▪ customize, measure, and improve the Website or content provided on or through the Website, or otherwise analyze or manage Elementary Curriculum Digitizers Incorporated’s business operations or Website performance;

▪ prevent prohibited or illegal activities, loss, or fraud, enforce Elementary Curriculum Digitizers Incorporated’s Terms of Use, or otherwise protect the security or integrity of the Website or Elementary Curriculum Digitizers Incorporated’s business;

▪ deliver targeted marketing, service update notices, or promotional offers based on Your communication preferences;

▪ send You things in the mail or through other channels, such as products or services that You have requested; register You for, or authenticate You when You sign into, an account or online services or when You purchase a product or service, or to provide You with notices about such accounts, subscriptions, or purchases;

▪ provide You notice about changes to the Website, this Privacy Policy, or Elementary Curriculum Digitizers Incorporated’s Terms of Use;

▪ otherwise fulfill the purposes for which You have provided Personal Information or that

were described when such Personal Information was collected; or

▪ carry out other purposes that are disclosed to You and to which You consent, or which

are otherwise permitted or required by law.

Elementary Curriculum Digitizers Incorporated may combine all the Personal Information Elementary Curriculum Digitizers Incorporated collects, including Yours, in order to analyze and understand aggregate trends.

Third-Party Transfers

Elementary Curriculum Digitizers Incorporated may transfer Your Personal Information to third parties that assist Elementary Curriculum Digitizers Incorporated with the use of Personal Information described in “Use of Personal Information by Elementary Curriculum Digitizers Incorporated”, above. Such third parties may combine Personal Information provided by Elementary Curriculum Digitizers Incorporated with other information that they have independently collected from or about You. Some third parties may be located outside of Canada and may accordingly be subject to laws that are different from those in Canada.

Elementary Curriculum Digitizers Incorporated requires that all third parties that received any Personal Information from Elementary Curriculum Digitizers Incorporated use the same standards as Elementary Curriculum Digitizers Incorporated in using, maintaining, disclosing, and protecting such Personal Information.

Elementary Curriculum Digitizers Incorporated may share aggregated, non-personally-identifiable information to third parties, to assist Elementary Curriculum Digitizers Incorporated to analyze trends about the general use of the Website.

Elementary Curriculum Digitizers Incorporated may share aggregated, non-personally-identifiable information publicly to show trends about the general use of the Website, or any content, services, or products provided on or through the Website.

Elementary Curriculum Digitizers Incorporated will not sell Personal Information, e.g., names and email addresses. Elementary Curriculum Digitizers Incorporated will not sell aggregated, non-personally-identifiable information to third parties.

Other Disclosures of Personal Information

Elementary Curriculum Digitizers Incorporated may disclose Your Personal Information if necessary to collect a debt from You or where Elementary Curriculum Digitizers Incorporated has reason to believe that such Personal Information is relevant to the investigation or decision to investigate a breach of the laws of Canada, a province or territory of Canada, or a foreign jurisdiction, and Elementary Curriculum Digitizers Incorporated is legally permitted or required to do so, or to otherwise comply with any court order, law, or legal process, including in response to any government or regulatory request or process, in accordance with applicable law. Elementary Curriculum Digitizers Incorporated may also disclose Your Personal Information, if necessary, to enforce this Privacy Policy or Elementary Curriculum Digitizers Incorporated’ Terms of Use, or if the disclosure is necessary to protect the rights, property, or safety of Elementary Curriculum Digitizers Incorporated, the Website, users of the Website, or third parties.

Elementary Curriculum Digitizers Incorporated may transfer information about You, including Personal Information, in connection with a merger or sale (including any transfers made as part of an insolvency of bankruptcy proceedings) involving all or part of Elementary Curriculum Digitizers Incorporated’s business or as part of a corporate reorganization or stock sale or other changes in corporate control.

ACCESS AND CORRECTION

You have the right to access Your Personal Information and to request a correction to Your Personal Information if You believe it is inaccurate. If You would like to access Your Personal Information, or have Your Personal Information corrected or deleted, please contact Elementary Curriculum Digitizers Incorporated in the manner set out by this Privacy Policy. Elementary Curriculum Digitizers Incorporated may charge You a fee to access Your Personal Information and will notify You in advance of any such fee.

Elementary Curriculum Digitizers Incorporated will provide You with access to Your Personal Information in accordance with applicable privacy legislation, and may decline to provide You access to Your

Personal Information on the basis that such Personal Information is:

▪ protected by solicitor-client privilege; or

▪ part of a legal proceeding, government or regulatory investigation or process, or otherwise part of a formal dispute resolution process.

Where Elementary Curriculum Digitizers Incorporated is unable to provide You with access to Your Personal Information, reasons will be provided subject to any legal or regulatory restriction.

You may have the right to withdraw the consent You have provided under this Privacy Policy in certain circumstances. To withdraw Your consent, if applicable, please contact Elementary Curriculum Digitizers Incorporated in the manner set out by this Privacy Policy.

DATA SECURITY

The security of Your Personal Information is important to Elementary Curriculum Digitizers Incorporated. Elementary Curriculum Digitizers Incorporated protects Your Personal Information by maintaining physical, organizational, and technological safeguards against unauthorized access, unauthorized disclosure, theft, or misuse appropriate to the sensitivity of such Personal Information. Personal Information collected by Elementary Curriculum Digitizers Incorporated may only be accessed by persons within Elementary Curriculum Digitizers Incorporated who require access to provide You with access to, use of, or content, services, or products provided on or through the Website. The Personal Information Elementary Curriculum Digitizers Incorporated collects is maintained at www.clickmelearning.ca within the Shopify Platform. Elementary Curriculum Digitizers Incorporated maintains digital records of Personal Information in a secure location in Ontario, Canada.

Although Elementary Curriculum Digitizers Incorporated takes measures to protect against data breaches and unauthorized access to Your Personal Information, no company can completely mitigate the risks of such breaches or unauthorized access and no website is fully secure. Elementary Curriculum Digitizers Incorporated cannot guarantee that hacking, data loss, breaches, or other unsanctioned access of Elementary Curriculum Digitizers Incorporated’s security systems will never occur. Accordingly, You should not submit or otherwise provide Personal Information to Elementary Curriculum Digitizers Incorporated by any means if You consider that Personal Information to be sensitive.

Except as otherwise permitted or required by applicable law or regulation, Elementary Curriculum Digitizers Incorporated retains Personal Information only for as long as necessary for the purposes for which such Personal Information was collected. Elementary Curriculum Digitizers Incorporated reserves the right to use anonymous and de-identified information, including anonymized or otherwise de-identified Personal Information, for any legitimate business purpose without further notice to You and without Your Consent.

CHANGES TO THE PRIVACY POLICY

Elementary Curriculum Digitizers Incorporated reserves the right to amend this Privacy Policy for any or no reason, at any time, and from time to time in accordance with the terms of this Privacy Policy.

Elementary Curriculum Digitizers Incorporated will reflect any such amendments on the Website. Your continued access to or use of the Website or any content on or though the Website after any such amendment constitutes Your acceptance of the Privacy Policy as then amended. Elementary Curriculum Digitizers Incorporated includes the date this Privacy Policy was last amended at the top of this page.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

Elementary Curriculum Digitizers Incorporated has appointed a privacy officer responsible for ensuring compliance with this Privacy Policy. If You have any questions regarding this Privacy Policy or Your Personal Information, please contact Elementary Curriculum Digitizers Incorporated’s privacy officer at Eileen White,℅ The Community Incubator, 279 10th St. E., OWEN SOUND, ON, N4K 1S4, or eileen@elementarycurriculumdigitizers.ca.