Effective date: December 2022

First Peoples Innovation Centre (collectively referred to as “FPIC” or “we“) takes the privacy of its customers, contractors, employees, subcontractors and visitors to its websites very seriously.

This Privacy Policy (the “Policy“) describes the manner in which we collect, use, disclose, process and maintain personal information in the course of our activities, including the operation of the site https://badgecipp.ca/en (the “Services” and the “Site“).
By accessing, registering, or using our Services or the Site, you consent and agree that information about you may be collected, used and disclosed in accordance with this Policy and our Terms and Conditions of Use.

If you do not agree to these terms, please do not use our Services. If you choose not to provide us with certain information that is required to offer you our Services, you will not be able to open a user account.

1. DEFINITION OF PERSONAL INFORMATION

Personal information is any information about an identifiable individual, either alone or in combination with other available information. This includes any information about you that you provide to us when you use the Site, such as when you create a user
account or complete a transaction.

2. SCOPE OF THE POLICY

FPIC is a Canadian corporation with its principal place of business in Quebec, and is subject to the Act respecting the protection of personal information in the private sector (RLRQ c. A-2.1). Certain personal information processing activities may also be subject to the Act respecting access to documents held by public bodies and the protection of personal information (RLRQ c. P-39.1) and the
European Union’s General Data Protection Regulation (2016/679 of April 27, 2016) (“GDPR”).

The Site may contain links to other sites published by other content providers. These other sites are not under our control and we are not responsible for the collection and use of your information by these sites. We encourage you to read the privacy policies of each site you visit and use.

3. PRINCIPLES APPLICABLE TO THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

Liability

FPIC is responsible for personal information it collects or holds, including personal information disclosed to third parties for processing and administrative purposes in accordance with this Policy.

3.1 Determining the purpose of collection

FPIC identifies the purposes for which it collects personal information at or before the time the information is collected. In the course of its activities, FPIC collects personal information in particular for the purposes of granting access and delivering the Services, as well as to comply with its legal obligations.

For information on the types of personal information collected on the Site and the purposes for which it is collected, see section 4 of this Policy.

3.2 Consent

FPIC collects, uses or discloses personal information with the consent of the individuals concerned, except where authorized or required by law.

3.3 Collection limits

FPIC’s collection of personal information is limited to that which is necessary for the purposes identified or clearly implied at the time of collection. FPIC may also collect and use information about you from third parties where permitted by law and with your consent in all other cases.

3.4 Limits of use and communication

FPIC does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. FPIC is committed to limiting disclosure and access to personal information to only those individuals who need it for the purposes for which it was collected.

We may share personal information with trusted agents and partners who act as subcontractors, including data processing, order fulfillment and publication, mailing and e-mailing, customer service and marketing services.

FPIC retains personal information only as long as it is reasonably required for the purposes for which it was collected or as required by law. Thereafter, the information is anonymized or destroyed in a secure manner.

3.5 Accuracy

FPIC makes reasonable efforts to ensure that the personal information it collects and holds is as accurate and complete as is necessary for the purposes for which it is to be used.
Please note that a request for rectification will only be considered if it is made in writing in accordance with section 9 of this Policy.

3.6 Security, hosting and storage

FPIC undertakes to apply and require its subcontractors to apply adequate physical, technological and administrative security measures in order to maintain the confidentiality of personal information and to protect it against theft, loss, disclosure or
unauthorized access.

Access to information system infrastructures and servers is secured by appropriate procedures and controls. Only duly authorized persons have access. They undertake to respect the confidentiality of personal information.

Our documents, including those containing personal information, are backed up at regular intervals. Once the legal retention period has expired, the data is deleted in accordance with current legal provisions.

Computerized logs, the integrity of which is assured, will be considered as proof of e-mail communications, registration form submissions, content downloads, content publications and comment postings.

No method of transmitting or storing electronic data is infallible, and we therefore cannot guarantee the security of information transmitted or stored through the Services. FPIC therefore cannot guarantee that there will be no intrusion into the Site or that the confidentiality, integrity or availability of your documents will not be compromised by another user or any other person.

Personal information collected or maintained by FPIC will be hosted and may be transferred or processed through equipment or facilities located in Canada or in the jurisdiction that we specifically indicate to you in connection with your use of our Services.

3.7 Transparency

This policy sets out FPIC’s personal information management policies and practices. Any changes affecting the protection of your personal information will be notified to users.

3.8 Access

Subject to applicable law, upon receipt of a written request from an individual in accordance with section 9 of this Policy, FPIC will advise the individual whether it holds personal information about him or her.

Upon receipt of a written request to this effect, FPIC will provide a summary of the use that has been or is being made of the information, inform the individual of the identity of third parties to whom it may have disclosed personal information concerning him or her and the purposes for which this information is transmitted to the third party.

FPIC may deny an individual access to his or her information in accordance with applicable laws, in which case FPIC will give reasons for its refusal, unless prohibited by law.

3.9 Complaints

An individual in respect of whom FPIC holds personal information may address a challenge concerning compliance with this Policy.

FPIC has established a procedure for receiving and handling complaints regarding this Policy and its personal information handling practices. Please note that a complaint can only be considered if it is made in writing in accordance with section 9 of this Policy.

If an individual is not satisfied with FPIC’s response to a complaint, or with FPIC’s personal information handling policies and practices, he or she may file a complaint with the Commission d’accès à l’information du Québec at https://www.cai.gouv.qc.ca/english/.

4. TYPES OF PERSONAL INFORMATION COLLECTED ON THE SITE AND PURPOSES OF COLLECTION

The personal information about you collected on the Site belongs to you.

This information is used to provide the services offered on the Site: delivery of digital badges, confirmation of purchase and registration (confirmed user profile), continuing education, peer-to-peer
exchanges, exchanges between the teaching team and learners, proactive sending of information, etc.

This information may also be used to send you updates on FPIC online continuing education topics or other events, to communicate with you about Site services, or to send you e-mail messages about Site maintenance or updates.
We will share the information we collect with third parties as follows:

1. With service providers or contractors who perform certain tasks on our behalf or on behalf of establishments. This includes information that you send to us and any transactions carried out through the operation of the Site;
2. With users of the Site, with respect to a digital badge awarded to you and the content associated with it, except insofar as you choose the option to keep the badge private (see the Site’s FAQ for the procedure to follow);
3. With other visitors to the Site, to the extent that you submit comments or other information or content to an area of the Site designed for communications with the public and with other members of a continuing education course in which you are participating. We may offer your contributions to learners who later enroll in the same courses, in forums, tutorials or otherwise. If you submit your contributions to us in non-public areas, we will publish them anonymously, except with your explicit permission, but we may use your user name to post them for the benefit of other members of your continuing education course;
4. To enable you to communicate with other users who may have similar interests or educational goals. This information sharing is in the perspective of networking in a community of common interest (on a given subject). For example, we may recommend partners for a specific discussion, as part of a particular training course in which you are enrolled. In such cases, we may use the information collected about you to determine who might be interested in communicating with you;
5. For the integration of third-party services. For example, videos and other content may be hosted on YouTube or other sites not controlled by FPIC; With the Ministère de l’Éducation du Québec, which has awarded a grant to FPIC to make its training courses available free of charge to all educational stakeholders in Quebec, for the purposes of reporting on access, engagement and completion of training by Quebec users;
6. With school principals or school boards, regarding the following information: the number of teachers in a school or school board who have registered on the site; the number of training courses completed by all teachers;
7. To any third party who is the organizer of an event, when a person’s participation in that event is attested via a digital badge: the number of attestations issued in connection with the event and the identity of participants.
8. To any third party that organizes and assumes the costs of a training course available on the Site, in order to report to it on the access, commitment and achievements of training course participants;
9. In order to respond to subpoenas, court orders or other legal process, in response to a request for cooperation from the police or other government agency, in the event of an investigation, to prevent or take action regarding illegal activities, fraud, for security purposes or against suspicious stakes techniques, or to enforce our Terms of Use, User Agreement or this Privacy Policy, as may be required by law or to protect our rights, property or safety or those of others; In addition, we may share information, which does not identify you personally, with the public and with third parties, including, for example, researchers and partners.

5. STATISTICAL DATA CONCERNING USE OF THE SITE

Usage data is data generated and collected by the Site concerning use of the Services. It is raw data, totally anonymized, used to produce statistics on the use of the Services and access to the Site, the analysis of which helps to improve the Services and the functionalities of the Site.

We collect this data when you create a user account, take part in further training courses (digital badges), send e-mail messages and/or participate in our forums. We record information such as which pages of our Site were visited, the order in which they were
visited, when they were visited and which links and other user interface controls were used.

We may record the IP address, operating system and browser used by each user of the Site. Various tools are used to collect this information.

Usage data may be used and shared with third parties:

1. To enable us to offer, manage and improve our range of continuing training courses.
2. To help us personalize the experience and evaluate the accessibility and impact of the Site in the international Frenchspeaking educational community.
3. For scientific research purposes, particularly in the fields of cognitive science and education.
4. To track individual and overall attendance, progress and completion of a course, and to analyze statistics on learner performance and how they learn and interact with the content on offer.
5. To detect violations of the Users’ Charter, the manner of use of the Site and fraudulent or potentially fraudulent use.
6. To publish information, but not personal data, collected by the Site about learners’ access, use, impact and performance.
7. To archive this information and/or use it for future communications with you.
8. To maintain and improve the operation and security of the Site and our software, systems and networks.
9. In the same cases of use and sharing as provided for in section 4 of this Policy with respect to personal information.

6. USE OF COOKIES

Certain information is collected by means of cookies (small text files placed on your computer which store information about you and which can be consulted by the Site).

A cookie does not enable us to identify you. Generally speaking, it records information relating to your computer’s browsing on our Site (the pages you have consulted, the date and time of consultation, etc.) which our system can read during your subsequent visits.

Please note that you can configure your browser to prevent cookies from being saved. Most browsers provide instructions for refusing them in the “Help” section of the toolbar. Please note that if you refuse our cookies, some functions and features of the Site may not function correctly.

7. RGPD: RIGHT OF THE DATA SUBJECT

To the extent provided by applicable laws where applicable, including the GDPR (General Data Protection Regulation) any data subject may:

• Withdraw consent at any time if processing is based on consent;
• Have personal information rectified, erased or deleted where appropriate; and

In addition, where the processing of information is based on consent, you have the right to receive your information in a commonly used electronic format or to ask us to deliver the data in this format to another supplier where your request relates to data you have given us directly and where it is technically possible to do so (data portability).

8. YOUR USERNAME AND YOUR PUBLICATIONS ON THE SITE

Please note that comments and other information you post in forums, message boards and other areas of the Site designed for public communication may be viewed and downloaded by other visitors. For this reason, we encourage you to exercise discretion before posting any information that could be used to identify you on these forums or other public or continuing education areas.

9. EXERCISING YOUR RIGHTS: OUR CONTACT DETAILS

Under the terms of this Policy, you have the right to access, withdraw and rectify your personal information.

To exercise these rights and for any request, question, concern or complaint regarding your personal information, this Policy or FPIC’s privacy practices, you should contact us by e-mail, via the “Contact Us” section of the Site or at badge@cipp-fpic.com or by mail at FPIC 3, place du Commerce, Suite 501, Nuns’ Island, Verdun, Quebec H3E 1H7. We will do our best to respond to such requests in a timely manner.

For countries in the European Union For the purposes of applying the RGPD, CIPP has appointed RESPONSIBLE PERSON as its representative within the European Union.

Questions can be sent to  badge@cipp-fpic.com.

FPIC address :
85B Promenade du Portage, Gatineau,
QC J8X 2K2
Telephone: 819 685-2424
E-mail: info@cipp-fpic.com

Last updated March 17, 2023