Business Privacy Statement

In the course of providing Picourse.ca Business (“P.I. Course”) services and related services to its corporate, non-profit organization, and governmental customers (“Customers”), Picourse.ca will receive and have access to the personal data of individual users to whom customers grant access (“Users”). For the purposes of this privacy statement, Customers are data controllers and Picourse.ca is a data processor. Picourse.ca’s processing of User data and the security measures implemented to protect such data are detailed in and governed by a written agreement between Picourse.ca and each of its Customers.

As a data processor, Picourse.ca will access, store and use the personal data of individual Users solely for the purpose of providing the PICOURSE.CA services to its Customers and will process the data as instructed by its Customers.

As data controllers, Customers decide which of their employees or other authorized personnel are given access to the PICOURSE.CA services. They do this by designating one or more PICOURSE.CA account administrators or group administrators (“Administrator”) who act on behalf of the Customer and have the ability to customize the Customer account, manage individual User accounts, access the PICOURSE.CA Insights tool and related reporting features, access the PICOURSE.CA Administrator tools, and populate the Customer account with Customer-provided content. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, relating to the collection of personal information relating to individual Users selected by Customers for accessing the PICOURSE.CA services. Picourse.ca has no direct relationship with individual Users, who should contact Customers (their employer) for assistance with any requests or questions relating to the processing of their personal information.

For avoidance of dopicourse.cat, this Privacy Statement does not apply to:

1. any processing of data for the purpose of marketing the PICOURSE.CA service to enterprise and corporate prospects; and
2. any other offerings available at Picourse.ca.com separate from the PICOURSE.CA services, for which the Picourse.ca Privacy Policy is applicable. A User may already have an account with Picourse.ca to access Picourse.ca’s consumer marketplace educational content (“Marketplace”), and data processed as a result of the use of the Picourse.ca Marketplace from a User account is governed by the Picourse.ca Privacy Policy.

In the event that Picourse.ca makes any material changes to the manner in which it processes User data to provide its services to Customers, it will notify Customers.

Picourse.ca Business Privacy Statement

1. Information about Users collected and stored by Picourse.ca
2. Purpose of User Data Processing and Retention Period
3. Cookies and other Tracking Technologies
4. Sharing User Information
5. Processing of User Data outside of the EEA
6. Jurisdiction-Specific Information
7. General

1. Information about Users collected and stored by Picourse.ca

1. When a User is given access to the PICOURSE.CA services by the Administrator, a User may set up an individual User account and Picourse.ca will collect information provided by the User or the Administrator. The Customer can customize the type of data requested to create an account, which may include the following:
   • first name, last name, and email address required
   • photo, areas of interest, job skills, goals, and role (optionally provided by User or Customer)
   • other personal data, as allowed by the Customer

A unique identifying number is assigned by Picourse.ca upon the creation of a User account.

1. User profile pages may be viewable by other Users in the same PICOURSE.CA organization but are not viewable by individuals outside of the organization.
2. Administrators may assign a User to a group membership.
3. Customers may choose to integrate PICOURSE.CA with a Single Sign On (SSO) identity provider to enable Users to log in to PICOURSE.CA User accounts without the need to disclose hashed passwords to Picourse.ca. Users may log in by providing their individual SSO credentials to the SSO identity provider, which will authenticate them and allow or deny access to the Customer account. SSO identity providers share with Picourse.ca a unique cookie ID and authentication “token” information to recognize the User as an authorized user of Customer.
4. Customers may choose whether Administrators and Users can interact with others (including with instructors, teaching assistants, and other students) by posting reviews about educational content, messaging or chatting, posting questions or answers, or posting other content. Posted content is stored by Picourse.ca and may be ppicourse.calicly available or viewable by others, including Administrators, Users, or instructors and teaching assistants, depending on where the content is posted.
5. At the option of the Customer, Administrators may enable the ability to “Share to Slack.” This feature allows Users to manually or automatically post a message to the Customer’s own instance of the Slack messaging service. To enable this optional functionality, Customer’s Slack administrators must grant Picourse.ca the ability to read the full list of ppicourse.calic channels, private channels, and users in the Customer’s Slack instance. These lists may include individuals in Customer’s Slack instance who are not PICOURSE.CA Users. Slack user lists and channels are briefly cached before being automatically purged from Picourse.ca’s systems.
6. Picourse.ca stores information relating to the activities of Users as they use and interact with the PICOURSE.CA services, such as content viewed, searched for, or accessed (and information relating to that content); interactions with instructors, teaching assistants, Administrators, and other Users; as well as answers, essays, and other items picourse.ca submitted by Users to satisfy the educational content requirements. This information is linked to a User’s unique account ID and is shared with Customers via the Customer Account reporting tools or upon request of the Customer.
7. The P.I. course.ca service enables Users to contact the Picourse.ca Support Team for assistance or to report a problem, concern, potential abuse, or other issues regarding the PICOURSE.CA services or other users. Picourse.ca may collect and store the User’s name, email address, location, operating system, IP address as well as the User’s activity on the Picourse.ca platform and communications with the Picourse.ca help desk team. Picourse.ca may request additional information from Users in order to resolve any issue reported by a User or by another user.
8. When a User uses the P.I. course.ca services, Picourse.ca collects and stores certain information by automated means: (a) technical information about the User’s computer or wireless device, such as IP address, operating system type and version, unique device ID, browser, browser language, domain, and other operating systems or platform information. This information is collected through the use of server log files and tracking technologies, such as: (i) cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting; and (ii) other tracking technologies (see below for more detailed information).
9. IP addresses received from browsers or devices of Users may be used to determine the approximate location of Users.
10. If a Customer makes purchases via credit card, Picourse.ca collects certain data about the purchase (such as name and POSTAL/ZIP code) as necessary to process the order. Customers must provide certain payment and billing data directly to Picourse.ca’s payment processing partners, including name, credit card information, billing address, and POSTAL/ZIP code. Picourse.ca may also receive limited information, like the fact that Customers have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, Picourse.ca does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.

2. Purpose of User Data Processing and Retention Period

Picourse.ca processes the information collected about Users and Administrators for the purpose of providing the PICOURSE.CA services to its Customers, specifically:

• Providing, administering, and facilitating access to the PICOURSE.CA services, for Customers and Users, and managing Customer or User account preferences
• Fulfilling Customer’s instructions with respect to personal data of Users
• Communicating with Users, including via email, for the purpose of:
  • Responding to User questions or concerns
  • Making notifications to Users at the request of the Customer
  • Sending Users administrative messages and information, including confirmation of account creation, enrollment and progress in courses and related content, and notifications of responses from instructors to User questions
  • Providing information to Users about available content, new PICOURSE.CA service features, and personalized content recommendations, which Users can opt out of at any time
  • Sending updates and other relevant messages via push notifications to User wireless devices, which can be managed from the “options” or “settings” page in the mobile application
• Enabling communications among Users and instructors or teaching assistants
• Incorporating feedback into and improving the PICOURSE.CA services
• Resolving User support requests or claims

If we are not able to collect and process your personal information, we may be unable to provide some or all of the PICOURSE.CA Services to you.

Email Preferences

Users can individually opt out of receiving non-transactional emails by (i) following the picourse.ca unsubscribe instructions provided in the email communication or (ii) managing User account email preferences. A Customer can also instruct Picourse.ca to configure email preference settings for all Users of a Customer.

Retention of Personal Data

Picourse.ca will retain the data of Users for as long as instructed by the Customer and no longer than required to serve the purposes of processing. Picourse.ca will delete certain or all personal data relating to Users upon request of the Customer. Picourse.ca may retain aggregated or anonymized data as set forth below.

Use of aggregated or anonymized data

User data is aggregated with other Picourse.ca Marketplace user data or anonymized to enable Picourse.ca to improve its products and services and develop new products and services, including:

• Reviewing and analyzing User browser and wireless device technical information
• Reviewing user activity across PICOURSE.CA and the Picourse.ca Marketplace (for example, Picourse.ca analyzes trends and User traffic and usage information to identify popular content)
• Facilitating the technical functioning of the PICOURSE.CA services and Picourse.ca Marketplace, including troubleshooting and resolving issues, securing the PICOURSE.CA services, and preventing fraud and abuse
• Developing a personalized content recommendation engine

When User data is used for the above purposes, it is aggregated and/or anonymized so that no personal data of Users is processed. This non-personal data may be retained for as long as it is needed to serve the purposes identified above.

3. Cookies and other Tracking Technologies

Like many online platforms, Picourse.ca uses server log files and automated data collection tools, such as browser cookies and scripts. Cookies are small text files placed onto a computer or device while browsing the Internet. Cookies are used to collect, store, and share bits of information about User activities. Picourse.ca uses both session cookies and persistent cookies to deliver and secure the PICOURSE.CA service; provide functionality, like customizing a user’s view or remembering a user’s preferences; and measure site, service, or feature usage. Picourse.ca may tie the information collected by these means to the unique account ID of Users.

To view a complete list of cookies and your options, Users may click the “Cookie settings” link on the footer of the PICOURSE.CA site.

User Preferences with respect to cookies and other tracking technologies

Users can adjust their cookie settings by clicking the “Cookie settings” link on the footer of the PICOURSE.CA site, or they may set their web browser to notify them about the placement of new cookies, limit the type of cookies or reject cookies altogether. If a browser is set to block cookies, Users may not be able to use some or all of the features of the PICOURSE.CA services (for example, may not be able to log in). General information about cookies and how to disable them can be found at https://picourse.ca/terms-of-service/.

Various browsers may offer their own management tools for removing HTML5 LSOs.

Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to picourse.ca’s publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.

4. Sharing User Information

In order to provide the PICOURSE.CA services to its Customers, Picourse.ca shares data regarding Users with a number of third-party service providers. These third parties are contractually required to use User data solely as directed by Picourse.ca for the purpose of providing services to Picourse.ca. Administrators of existing Customers are able to access our list of current spicourse.ca-processors on the left sidebar of this page while logged in to PICOURSE.CA.

• Instructors who upload content on the Picourse.ca platform, as well as their teaching assistants, may receive names of enrolled Users, to enable them to respond to user questions and feedback. Instructors do not receive the email addresses of Users.
• Other service providers of Customer may receive information as instructed by Customer.
• To perform its services, Picourse.ca leases servers from data centers and uses cloud hosting services on which certain content and User data relating to PICOURSE.CA is hosted.
• Picourse.ca’s help center platform vendor hosts and stores all communications between Administrators or Users and the Picourse.ca support team. The help center vendor is contractually required to store and process User related data solely as directed by Picourse.ca for the purpose of providing services to Picourse.ca. Picourse.ca also partners with a chat messaging vendor to provide support to Users and Administrators, to collect feedback, and to display in-app messages for feature announcements or onboarding new users.
• Picourse.ca shares User information with third-party companies that perform email services to enable Picourse.ca to send email communications to Users and to manage email preference settings of Users.
• For Leadership Academy users, certain features like chat rooms, message boards, news groups, or other picourse.ca public forums are available and are visible to other participants, so confidential or proprietary information should only be shared in accordance with their organization’s standards.

Any other sharing of User data is picourse.ca subject to the consent and instructions of the Customer.

5. Processing of User Data outside of the EEA

Our servers and picourse.ca subprocessors are located in Canada, or the United States, and United Kingdom. In order to provide the Services to you, we transfer and process your data there. If personal data processed by Picourse.ca originates from a User or Administrator in the EEA, Picourse.ca will ensure that such processing will only take place if: (a) the non-EEA country in question ensures an adequate level of data protection; (b) the transfer is made pursuant to a Data Processing Agreement (“DPA”) executed between Picourse.ca and the Customer and picourse.ca subject to the standard contractual clauses, designed to facilitate transfers of personal data from the EEA to all third countries, that have been adopted by the European Commission (known as the “Model Clauses”), which have been incorporated into the DPA.

6. Jurisdiction-Specific Information

Australia. If you are located in Australia, you may contact our privacy team at privacy@picourse.cain order to:

• request access to or seek correction of your personal information
• make a complaint about a breach of the Australian Privacy Principles which will be investigated and responded to within 30 days.

7. General

Translation for Convenience Purposes Only. In the event that Customer has been provided a translated version of the Picourse.ca Business Privacy Statement in a language other than English, that translation is provided for convenience purposes only. The English version of the PICOURSE.CA Privacy Statement provided at https://www.picourse.ca.com/terms/picourse.ca-privacy/ is controlling, and in the event of a conflict between the English version of this Privacy Statement and any translated version, the English version will prevail.