Privacy Policy



HomeLearners Network Privacy Policy

Last Updated July 28th 2022


At HomeLearners Network, operated by SelfDesign Learning Foundation, we are committed to providing our users with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our users, protecting their personal information is one of our highest priorities.


Respecting our users' privacy and safeguarding their personal information is at the core of everything we do. We abide by British Columbia’s Personal Information Protection Act (PIPA), which came into effect on January 1, 2004, and sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information. In addition, we are committed to meeting or exceeding privacy requirements that may apply based on the jurisdictions that our users reside in.


We will inform our users of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.


This privacy policy outlines the principles and practices we will follow in protecting users’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our users' personal information and allowing our users to request access to, and correction of, their personal information.

Definitions

Personal Information information about an identifiable individual, such as an email address, name, or phone number. Personal information does not include contact information (described below).

Work contact information – information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPA.
Privacy Officer – the individual designated with responsibility for ensuring that HomeLearners Network complies with this policy and PIPA. 

Participant - a learner who is using the HLN Services and that is between the schooling grade levels of Kindergarten through Twelfth Grade.

Parent - a parent or legal guardian of a Participant who is at least 18 years old who completes HLN’s account registration process for the purpose of enrolling a Participant to the HLN Services through the Site.

User - a Participant or Parent that is using or has used HLN services.

HLN Guide - a person who creates, plans, and hosts Realtime, At-Home Activities or creates Anytime, At-Home Activities for Participants through the Site.

Realtime, At-Home Activities - synchronous online activities.

Anytime, At-Home Activities - asynchronous activity packages.

Online Camps - synchronous online camps based on specific themes and skills.

Website - The HomeLearners Network Website operated by SelfDesign Learning Foundation.

Cookies -  small text documents or pieces of code which may include an anonymous unique identifier. When you visit a website or use a mobile application, your computer or mobile device may be asked for permission to store this file on your computer or mobile device and access information from it. This may include information you may have voluntarily given while visiting the website, such as an email address.


1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the user voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection. 

1.2  We will collect user information, such as name and email address, that is necessary to fulfill the following purposes: 

    • - To verify identity;
    • - To identify user preferences;
    • - To open and manage an account;
    • - To deliver requested products and services;
    • - To enrol the user in an activity;
    • - To meet regulatory requirements;
    • - To ensure a high standard of safety and professionalism in our activities;
    • - To email Parents information about HLN offerings (you can use the unsubscribe link in emails that we send you if you do not wish to receive these emails).

 

If we collect user information for any other purposes, we will obtain consent at the time of collection.

1.3 Specifically, HLN network collects the following personal information:

Personal Information Category

Purpose and Details

Parent full name

For the purpose of providing HLN products and services.

Parent email address

For the purpose of providing HLN products and services.

Participant first name

To enable HLN guide to provide age-appropriate, skill-appropriate, and real-time activities.

Participant date of birth

To enable HLN guide to provide age-appropriate, skill-appropriate, and real-time activities.

Participant pronouns

To enable HLN guide to address the child the way they wish during real-time activities.

Participant interests (optional)

To enable HLN guide to provide age-appropriate, skill-appropriate, and real-time activities.

Reading level

To enable HLN guide to provide age-appropriate, skill-appropriate, and real-time activities.

Support areas  (optional)

To enable HLN guide to provide support to participants, such as by allowing extra time for processing oral information, offering approaches to self-regulation through behavioural adaptations, or by providing frequent breaks.

Billing address

In order for parents to pay for HLN services/products, Shopify processes this information.

Credit card

In order for parents to pay for HLN services/products, Shopify processes this information.

Website user device and behaviour data (cookies)

A limited range of cookies collect website user device and behaviour data. See section 10 for more details.

2 – Consent

2.1  We will obtain user consent to collect, use or disclose personal information. Further, HLN requires verified parental consent in order to collect personal information of children, in keeping with applicable data protection laws. Parents must declare that they are a parent/legal guardian of at least 18 years of age, and must provide consent for their child to be a Participant in order to enrol them in HLN activities. A credit card transaction is used to verify the Parent’s identity.

2.2  Consent can be provided in writing at the time of creating an account by taking an affirmative opt-in action, such as checking an agreement to the Terms and Conditions  and Privacy Policy. Consent can also be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the user voluntarily provides personal information for that purpose. 

2.3  Subject to certain exceptions (e.g. the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), users can withhold or withdraw their consent for HomeLearners Network to use their personal information in certain ways. A user's decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the user in making the decision. 

2.4  We may collect, use or disclose personal information without the user's knowledge or consent in the following limited circumstances: 

- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual's life, health, or personal security.
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law;
- If HLN is involved in a reorganization, merger, acquisition, sale of our assets, bankruptcy dissolution, or other similar transaction or proceeding, your personal information may be transferred as part of that event. We will notify you of and outline your choices in such an event, when applicable.

    3 – Using and Disclosing Personal Information

    3.1  We will only use or disclose user personal information where necessary to fulfill the purposes identified at the time of collection, or for a purpose reasonably related to those purposes (such as to conduct user surveys in order to enhance the provision of our services).

    3.2 We transfer personal information to third parties that provide support for the internal operations of HomeLearners Network. In these cases, we take appropriate steps to ensure that the information is securely processed. These third parties include:

    - Shopify, our website e-commerce platform (Read: Shopify privacy policy, cookie policy and data protection addendum);

     
    - Azure, a Microsoft cloud computing service to provide backend functionality to the Shopify platform for specific user features. (Read: Azure privacy policy and data protection addendum);

     
    - Omnisend, to send emails and notifications to users (Read: Omnisend privacy policy and data protection addendum)

     
    - Vimeo, to stream Guide videos embedded in our website (Read: Vimeo privacy policy, cookie policy, and data protection addendum)

     
    - Zoom, to host live activities (Read: Zoom privacy policy and data protection addendum). 

     
    - Google Analytics, to understand how users use our website (Read: Google privacy policy).

    - Accessibly, an accessibility platform for ADA & WCAG compliance (Read: Accessibly privacy policy

    Corner by Messengerify Labs PVT LTD, to display frequently asked questions on the HLN website (Read: Corner privacy policy and data protection addendum.)

     

      3.3 HomeLearners Network is based in BC, Canada, but information transferred to third parties may be processed outside of Canada. As a result, personal information provided to HLN may be processed in a foreign country, and it may be accessible to law enforcement and national security authorities of that jurisdiction. Your acceptance of the privacy policy and Terms and Conditions represents your agreement to that transfer.

      3.4  We will not use or disclose user personal information for any additional purpose unless we obtain consent to do so. 

      3.5  We will not sell user lists or personal information to other parties. 

      3.6  HLN and HLN contractors will not share images, video or voice recordings, personal details/data about Participants on social media without written consent from the Parent, as well as written consent from the Participant if they are 13 years of age or older.

      3.7 HLN may offer links to other sites that are not operated by us as an option to enrich experiences during the activities we offer. Users can always decline to use these services. Anytime a User clicks a third-party link, they will be directed to that third party’s site. We strongly advise Users to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. Some common sites that we link include:

      - Padlet, to collaborate with Participants and obtain their answers to questions (Read: Padlet privacy policy)

       
      - PearDeck, to collaborate with Participants and obtain their answers to questions (Read: Peardeck privacy policy)

       
      - Kahoot, to collaborate with Participants and obtain their answers to questions (Read: Kahoot privacy policy)

       
      - Instapage, for hosting marketing landing pages for ads (Read: Instapage privacy policy)

         

        4 – Retaining Personal Information

        4.1  If we use user personal information to make a decision that directly affects the user, we will retain that personal information for at least one year so that the user has a reasonable opportunity to request access to it. 

        4.2  Subject to policy 4.1, we will retain user personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose. 


        5 – Ensuring Accuracy of Personal Information

        5.1  We will make reasonable efforts to ensure that user personal information is accurate and complete where it may be used to make a decision about the user or disclosed to another organization. 

        5.2  Users may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. 

        5.3  If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year.  If the correction is not made, we will note the users' correction request in the file. 


        6 – Securing Personal Information

        6.1  We are committed to ensuring the security of user personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. 

        6.2  The following security measures will be followed to ensure that user personal information is appropriately protected: 

        • - The use of passwords; 
        • - encryption; 
        • - firewalls; 
        • - restricting employee/contractor access to personal information as appropriate (i.e., only those that need to know will have access)); 
        • - privacy training for administrators and developers;
        • - using data protection addendums when using third-party services where necessary;
        • - contractually requiring any service providers to provide comparable security measures.
        •  

        6.3  We will use appropriate security measures when destroying user's personal information such as by deleting electronically stored information. 

        6.4  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security. 


        7 – Providing users Access to Personal Information

         7.1  Users have a right to access their personal information, subject to limited exceptions, such as:

        - The disclosure would reveal personal information about another individual, and that individual does not consent to the disclosure.
        - The disclosure can be reasonably expected to cause immediate and serious harm to the health of the user requesting the information, or to another individual.
        - Information that is protected by solicitor-client privilege.
        - Information that is part of a formal dispute resolution process.
        - Information that is prohibitively expensive to provide.

         

        7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. 

        7.3  Upon request, we will also tell users how we use their personal information and to whom it has been disclosed if applicable. 

        7.4  We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. 

        7.5  A minimal fee may be charged for providing access to personal information.  Where a fee may apply, we will inform the user of the cost and request further direction from the user on whether or not we should proceed with the request. 

        7.6  If a request is refused in full or in part, we will notify the user in writing, providing the reasons for refusal and the recourse available to the user. 

        7.7 A Parent can review or request deletion of the personal information belonging to them or Participants on their account by emailing the privacy officer (see contact details are below). They may also refuse to permit its further collection or use.


        8 –  Updates to this privacy policy

        8.1  This privacy policy may be modified or revised from time to time. We will notify users of any changes to this privacy policy by posting the revised version with an updated date of revision on our website. If we change this policy in a material manner, we will do our best to notify you of the changes by posting a notice on our website. Your continued use of the services constitutes your acceptance of the revised policy.


        9 – Children and Privacy

        9.1  Protecting the privacy of children is a core priority of HLN. For that reason, HLN does not permit Participants to enrol in activities without the consent of a Parent user. HLN will take appropriate steps to remove any personal information of children provided without verified parental consent. Any related concerns can be emailed to the privacy officer (see contact details below).


        10 – Use Of Cookies And Digital Tracking

        10.1 HLN may use information collected through cookies and similar digital tracking technologies in order to provide better technical support, and for metrics that we use to enhance the user experience. For instance, we use cookies to track:

        - Whether a user is signed in or has previously signed in so that they can access personal user features.
        - Browser and online usage patterns (such as user IP address, browser type, device type, mobile carrier, pages viewed, and links clicked.

         

        10.2  On a limited basis, HLN may use third party advertising tracking on pages directed to adults to inform our digital marketing and help us connect with people who are interested in our service and our mission. For instance:

        - When a verified Parent has made a purchase, we may use a tracking pixel on the purchase confirmation page.

         

          10.3  HLN services may store and access cookies on your computer or other devices. For more information and a full list of cookies and tracking technologies, click here.

          10.4 If you wish to block or delete cookies, you can do so by using Cookiebot when you first visit the HomeLearners Network , as well as setting your browser settings to disable non-essential cookies. However, if you do not accept cookies, you may not be able to use some portions of our Service.

          10.5 Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.


          11 – Questions and Complaints:  The Role of the privacy officer or designated individual

          11.1  The privacy officer is responsible for ensuring HomeLearners Network’s compliance with this policy and the Personal Information Protection Act. 

          11.2  Users should direct any complaints, concerns or questions regarding HomeLearners Network’s compliance in writing to the privacy officer. If the privacy officer is unable to resolve the concern, the user may also write to the Information and Privacy Commissioner of British Columbia. 

          11.3  Contact information for HomeLearners Network Privacy Officer or designated individual:


          Cimarron Ballantyne

          Privacy Officer

          SelfDesign Learning Foundation

          PO Box 74560 RPO

          Kitsilano

          Vancouver, BC V6K 4P4 Canada

          privacy@selfdesign.org