Privacy and Cookie Policy
This Privacy and Cookie Policy (“Policy”) describes the personal information that Coeuraj Management Inc., 1302724 B.C. Ltd., Watershed US Inc. (“Coeuraj”, “Coeuraj group of businesses”, “we” or “us”) collects from or about you when you use our applications, websites, and services, including web interfaces and applications for mobile devices, or participate in Coeuraj organized events(collectively, the “Services”). It also describes how we use that information, and to whom we disclose it. “Personal information” means information about an identifiable individual. Personal information does not include information about a corporation or entity other than a natural person.
Please read this Policy carefully. If you do not agree with this Policy, you should not access or use our Services or applications, and you may also adjust certain of your preferences as described in this Policy. This Policy should be read in conjunction with our Cookies “banner”.
Privacy Policy Summary
What Personal Information we collect.
The personal information we collect depends on how you interact with us. If you are our client, or participate in one of our sessions, or agree to receive our communications, we collect information such as name, contact information, including email address, job title and role, payment information, and information you choose to provide, such as your contributions to a session, or your ideas or opinions, including with your consent a transcription of the session.
If you visit our website, we collect technical information such as IP address, internet service provider, browser and operating system version and type, the date, time and duration of your visit, general geographic region, information from server and traffic logs, bounce rate, device type and information, use frequency, how you access the Services, visitor numbers, the portions of our site viewed and links clicked, language preference, demographics, and interests.
How we Use the Personal Information we collect.
We use personal information to provide our Services, for example by allowing you to participate in a session, and for project planning, management and execution. We also use personal information to communicate with you and provide you with information, to understand the use of our services, to establish and maintain our business relationship, for our internal business purposes, such as administering or improving our Service, or to develop new ones, to conduct market research, to enforce any agreement we have with you, to protect our interests, and to comply with legal requirements.
We use technical informationto understand how users use and access our Service, to improve the Service, and deliver a faster, better experience, and for system administration and security purposes. We also use this information to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about Service usage, to allow us to remember return visitors and their settings and preferences, set access privileges, provide website functionality, track website usage, and identify usage trends.
How we share the Personal Information we collect.
We may share information with third party service providers that assist us with carrying out the practices we describe in this policy. We may also share information where there is a legal requirement or to protect our rights or interests, such as with law enforcement, or if we are required or permitted to do so by law. We may also disclose information if we undergo a business transaction, such as a sale or merger.
Your Choices.
If you receive commercial email from us, you may unsubscribe using the tool we provide in those messages. For information on how to opt-out of the tools of some of our analytics service providers, please see: Information Collected through Automated Means below. You may also reject cookies, though it may affect your experience.
This Policy May Change
We may modify this Policy from time to time. We will provide you with notice of any material changes to this Policy by publishing or communicating the changes through our Services or by other means so that you may review the changes before continuing to use our Services. Your continued use of the Services after we publish or communicate a notice about any changes to this Policy means that you are consenting to the changes.
Accountability, Openness and How to Contact Us
Coeuraj is responsible for personal information under our control.We have established policies and procedures to help safeguard any confidential personal information that we have on file or which we collect, and to deal with complaints and inquiries.
Coeuraj has designated a chief privacy officer (“Privacy Officer”) who is accountable for the protection of personal information we control. All questions, concerns or complaints regarding this Policy, and our compliance with it, should be directed to the Privacy Officer in writing and sent by email to info@coeuraj.com.
or by mail to:
Privacy Officer
Coeuraj Management Inc.
850 Courtney St
Victoria, BC
Canada V8W 1C4
Every complaint or challenge regarding our compliance with this Policy will be investigated and, where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary.
Your Consent
By submitting your personal information or otherwise using the Services, you signify your agreement to the terms and conditions of this Policy and to our collection, use and disclosure of your personal information in accordance with this Policy. You may make inquiries, or change or withdraw your consent to the collection, use and/or disclosure of your personal information at any time by contacting the Privacy Officer in writing at either of the addresses listed above (see: Accountability and Openness / Compliance). You may also be alter your preferences using tools we make available to you. For example, you can unsubscribe from our commercial email by using the “Unsubscribe” link we include in such communications.In some circumstances, particularly where our use of your information is integral to the provision of a Service, a change or withdrawal of consent may affect your ability to use and/or our ability to provide you with certain information, products or services.
Collection of Information
What Information is Collected and How?
Generally, we collect personal information as necessary for the purposes set out below (see: Purpose - Why We Collect, Use and Disclose Information).In most cases, we will collect personal information directly from you when you interact with us with respect to our Services, websites, events, or any other product or service that we offer. In some cases, we may collect personal information from a third party, such as your employer or another licensee of a Service that you are using. For example, our clients may provide us with the names and contact information of their employees and representatives whom they would like to participate in one of our sessions. If you are providing us with personal information of a third party, you must ensure have any consents necessary to provide us with such information for the purposes for which it is provided, or must be otherwise permitted by law to do so. Personal information will always be collected using means that are fair and lawful.
Information collected in connection with the use of our Services includes the following:
- The name and contact information, including email address, job titles and roles, for our clients, as well as for individuals who participate in our design sessions, or who choose to subscribe to our email communications;
- Information to allow us to identify and provide services to our clients, including payment information;
- If you participate in one of our sessions, we may collect information discussed in that sessions, such as your ideas and opinions, to allow us to carry out our Services. With your consent, if you participate in a virtual session, we may use a voice to text transcription tool made available through the platform on which the session is held to create a written transcript of the session. This is used to provide the Services.
- Other information you choose to provide to us, such as information including your opinions and feedback, you provide if you respond to one of our surveys, or otherwise provide this to us following a session.
Information Collected through Automated Means
Device Information: We collect certain information related to a user’s use of our Services including the Internet Protocol (IP) address of the user’s computer or device, the user’s Internet service provider (ISP), the type and version of the browser that the user is using, the date and time the user accessed the Service, and the operating system that the user is using. We use this information to understand how users use and access our Service, to improve the provision of the Service, and to deliver a faster, better, experience. We may also review server logs and traffic on the Services for system administration and security purposes, for example to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about usage. The possibility therefore exists that server log data, which contains users’ IP addresses, could be used in instances of criminal, fraudulent, or other improper activities such as security breaches, to trace and identify individuals. In such instances, we may share raw data logs and other information with the appropriate authorities for the purpose of investigating such matters.
Cookies: “Cookies” are small text files that are placed on your computer by websites that you visit. They are used to identify you to the web server, and will tell the server who you are when you return to a page on the same website. Session cookies expire when you close your browser. Persistent cookies remain on your device until they are deleted or expire. We may use cookies to determine and facilitate your access privileges on our website or to our Services, to complete and support a current activity, to track website usage such as the number of visitors to our Services, the time of those visits, the portions of Services visited, the links clicked, to remember your language and other preferences, and to generally improve your experience.
Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent. If you decline cookies, you will still be able to use the website or the Services, but your ability to access certain features and functions may be affected. To find out more about cookies, including how to see what cookies have been set and how to manage and remove them, please visit AboutCookies.org or All_About_Cookies.org.
Google Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services, and to report on activities, trends and user behavior patterns. We do this to obtain an overview of how people are accessing and using the Site, and to identify trends in usage of our Services. Information that we use from Google Analytics includes: the number of visitors to the Services, IP address and general geographic location; viewing patterns such as time per page; pages per session; bounce rate; device type and information; frequency of use; how the Services are accessed (e.g. by search engine, or from a link); language; demographic; and interests.You can learn about Google’s practices by going to www.google.com/policies/privacy/partners. You can opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Purpose - Why We Collect, Use and Disclose Information
We will identify the purposes for which we collect personal information before or at the time we request the information, or if we ask you for further consent. The information that we collect is used and disclosed only for these purposes, but only when there is a legal basis to do so. The business purposes for which information may be used include:
to enable you to access, participate in and/or use the Services (see: What Information is Collected and How);
to further the delivery of Coeuraj’s technology and related services, including but not limited to, the facilitation of project planning, management and execution, and both client sessions and events regarding our Services;
to process, track and communicate with you about usage of the Services;
to establish, maintain and manage business relations with you or the company or legal entity you are employed by or represent;
to provide you with the information, products or services that you request;
for internal business purposes, such as administering or improving the Services, or developing new services;
to perform internal market research and to contact you to conduct polls and surveys;
to obtain feedback regarding the Services and our ability to address the needs of our users and Coeuraj event participants;
to provide our users and Coeuraj event participantswith information and promotional materials regarding Coeuraj and Coeuraj’s products and services;
to enforce our terms of service, protect us against error, fraud, theft or damage to our business or our property;
to comply with any legal, accounting and regulatory requirements, including reporting requirements, applicable laws, and any search warrants, subpoenas or court orders; and
any other reasonable purpose for which you provide consent.
Where personal information that has been collected is to be used for a purpose not previously identified, and for which consent cannot be reasonably implied, the new purpose will be identified and consent obtained prior to the use of that information for the new purpose unless otherwise permitted by law.
We may anonymize, aggregate or otherwise strip any personal information or other information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purpose we deem appropriate.
Legal Basis for the Use of Your Personal Information
We will only process your personal information where we have a legal basis to do so. The legal basis will depend upon the reason or reasons that we collected and require the use of your information. The legal bases upon which we will use your information will generally be one of the following:
The performance of the contract that we have with you or the licensee of the Services, including for the purpose of allowing you to access and use our Services.
Our legitimate interests, such as providing you with the best Services, to enhance user experience, improve our services and events, and for administrative, fraud detection and legal purposes.
To comply with legal obligations.
To protect your vital interests, or those of another natural person.
Because you have consented to our use of your personal information for particular purposes, such as the creation of a user accounts in order to access our Services. You may withdraw your consent at any time by contacting the Privacy Officer at the address set out above (see: Accountability and Openness / Compliance). In jurisdictions where legitimate interests are not a basis on which personal information may be processed, by submitting your personal information or otherwise using the Services, you signify your consent this Policy and to our collection, use and disclosure of your personal information in accordance with this Policy and any preferences you have expressed.
Disclosure to Third Parties
Your personal information may be transferred or disclosed as provided in this Policy or permitted or required by law.
You acknowledge that, in the course of providing the Services to you, we may delegate our authority to collect, use or discloseyour information to third party subcontractors. For example, third party subcontractors may include web hosts, payment processors, delivery and logistics providers, and social network integrators. More information regarding the personal information that we make available to our third party contractors, and how it is used, is available by contacting the Privacy Officer at the address set out above (see: Accountability and Openness / Compliance). Any request made by you to correct, change or erase your personal information will be promptly communicated to any third party subcontractors in possession of that information.
We may disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, for example, due to government request, request of a law enforcement agency, search warrant, subpoena or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request, warrant, subpoena or court order, or to protect our business or assets, other users of the Services, or the public.
Subject to certain restrictions and unless prohibited by law, Coeuraj may also use and disclose your personal information without your knowledge or consent where necessary in connection with a proposed or completed business transaction, such as if we, or a portion of our business is acquired by or merges with another entity.
Safeguards – How Information is Protected
We have implemented physical, organizational, contractual and technological security measures to help protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information. These protections may include the use of user IDs, passwords, and encryption technology. Our employees, representatives, and contractors who have access to personal information are those having a “need to know” that information for the purposes set out in this Privacy Policy, and other persons who may be required or permitted to access it under applicable law. The personal information we control is managed from our offices in Victoria, British Columbia. No security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. As a result, we cannot ensure or warrant the security of any information you provide to us. Therefore, by using the Services, and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.
Accuracy / Access / Portability / Erasure
Subject to exceptions under the applicable law, you have a right to access, and request correction of, your personal information that we hold. You may make a request in writing for access to your personal information or request to correct it if you believe it is inaccurate by contacting our Privacy Officer at the address set out above (see: Accountability and Openness / Compliance). Subject to exceptions permitted by law, you may also request that any personal information in our possession be transferred to yourself or to another data controller.
You may request the erasure of your personal information at any time which, subject to our need to invoke any exceptions permitted under applicable law, we will endeavor to do without undue delay as required by applicable law. Written requests should be sent to the Privacy Officer at the address set out above.
Including “Request personal information” in the subject line of your email will facilitate compliance with your request to access or transfer your information.We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed.
In certain circumstances, Coeuraj may not be able to provide you with access to all or some of your personal information, in which case you will be advised in writing of the reasons for our inability to provide you with the information.
If you demonstrate the inaccuracy or incompleteness of your personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, if your personal information changes. Except as provided by applicable law, you may ask that we erase any of your personal information without undue delay, particularly in cases where the information is no longer required by us, you no longer consent to our use of your personal information, or if our use was in violation of this Policy or applicable law.
To help protect against fraudulent requests for access to your personal information or other requests regarding it, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access or taking other action. For example, we may require you to verify your identity before you access your personal information.
All notices and requests regarding inaccuracies, changes or erasure should be in writing and sent to the Privacy Officer at the addresses set out above (see: Accountability and Openness / Compliance).
International Transfer and Storage of Information
You acknowledge and agree that your personal information may be transmitted, transferred, processed, and/or stored outside of Canada, including in the United States. We cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States or other countries according to their laws. By submitting your personal information to us, you consent to the transmission, transfer, processing and/or storage of your personal information outside of Canada. If you have any questions regarding our use of service providers outside of Canada, you may contact us using the contact information we provide above.
Third Party Content and Links to other Websites
The Services may contain links to third party Internet websites and services. These third party websites and services are not controlled by Coeuraj, and we are not responsible for their actions. You acknowledge that these third parties may collect data from users or their computers. The accessing and use of third party websites or services is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites or services. This Policy applies only to the Coeuraj Services, and we encourage you to review the privacy policies of any third parties when using their websites or services.
Minors
Minors (persons under the age of majority as defined in your jurisdiction) are not eligible to use the Services unsupervised, and we request that minors do not submit any personal information to us. If you are under the age of majority in your jurisdiction, you may only use the Services in conjunction with and under the supervision of a parent or guardian. Coeuraj does not knowingly collect personal information from minors under 13 or such other age where parental consent is required by law without parental consent.
Governing Law
To the extent permitted by applicable law, and for users who are not individuals resident in Quebec, you agree that your access to and use of the Coeuraj Services and website, and this Policy, are governed exclusively by the laws of the Province of British Columbia and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles). In case of any inconsistency between this Policy, and applicable law, applicable law shall prevail and this Policy shall be interpreted so as to apply only to the extent permitted by law.