The purpose of this Privacy Statement is to inform you about the types of personal information Mirage Spa Education Inc. (as follows, “Mirage Spa”, “we” or “us”) collects, uses and shares when you visit or interact with miragespa.ca (the “Site”). It explains how we use and disclose that information, the choices you have regarding such use and disclosure and how you may correct that information.
We are proud to demonstrate our commitment to your privacy by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.
1. Collection of Personal Information
b. What is personal information?
Personal information is any factual or subjective information about an identifiable individual (“Personal Information”). Your personal information may include but is not limited to your name, mailing address, phone numbers, gender, email address, identification numbers, etc. Personal Information, however, does not include any information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work electronic address.
c. What Personal Information do we collect?
When you visit our site, we automatically collect certain information about your device, including information about your IP address, web browser, time zone, and some of the cookies that are installed on your device.
Additionally, we collect information about how you interact with the Site, including, the individual webpages or products that you view, any terms you might search, and how many times you’ve visited our site, referring and existing pages, date and time stamps, transmitted data volume, operating system and other technical data such as details of your visits to
our website. We refer to this automatically-collected information as “Device Information.” When we refer to Personal Information, we are also talking about Device Information, unless we address Device Information specifically.
We also collect Personal Information that you may provide to us, including; your basic personal details such as your name and job title; contact data such as your telephone number, postal code, or email address; and demographic data such as your address, preferences, interests, and other personal information relating to you that you may provide. We do not collect information that is identifiable to children. When we do, it is on a limited basis and with the expectation of adult supervision or permission. In such cases, we strictly limit the use of that personal information to the purposes for which it was collected. We recommend that parents and guardians take steps to limit and monitor their children’s Internet activities directly, or through software and other tools.
d. When and how do we obtain consent?
e. How do we use technology to collect information through the Site?
We collect Device Information using the following technologies:
- (i) We Use “cookies” or a similar technology to assist us to customize the Site. A “cookie” is a data file that is placed on your device and often includes an anonymous unique identifier. Cookies do not damage computer systems or files, and only the website that transferred a particular cookie to you can read, modify, or delete such cookie. Most of the cookies we use are so-called “session
cookies”, which are automatically deleted at the end of your visit. Other cookies will remain on your device until you delete them. These cookies enable us to recognize your browser the next time you visit us.
- (ii) We use “Log Files” to track actions that occur on the site and collect data including your IP Address, Internet Service Provider, referring and exiting pages, date and time stamps, and browser type.
- (iii) We use “Web beacons,” “tags,” and “pixels” which are electronic files used to unobtrusively record information about how you browse the Site. These are used in conjunction with our service providers for the purposes of analyzing what content you view on our site.
Additionally, when you register for courses, we may collect certain information from you including your name, driver’s licence information, SIN, billing address, shipping address, and payment information (including credit card number). We refer to this as “Registration Information.”
f. What Cookies we use?
We use the following cookies:
- i. Strictly necessary cookies: Without these cookies, it would be impossible to use the service as they are required in order to perform basic tasks on the website.
- ii. Preferences cookies: These cookies store the user’s preferences while navigating the Site. We use preferences cookies in order to store user choices like which diploma programs he/she wants to consider.
- iii. Analytics cookies: Analytics cookies help us extract information related to the way our users use our websites, with the aim of improving our services.
2. Use of Personal Information
a. How do we use your Personal Information?
When we refer to Personal Information, we are talking about both Device Information and Registration Information.
We may collect your Personal Information for a variety of reasons, including: sending you information and communications; responding to course inquiries and other requests; conducting contests and promotions; processing transactions; optimizing your experience on our Site; arranging for shipping; providing you with invoices and registration confirmations; screen payments for potential risk or fraud; and to assess the success of our marketing and advertising campaigns.
We may also use your Personal Information as otherwise permitted by law. Registration Information that is exclusive of Device Information shall only be disclosed to governmental authorities with jurisdiction, including the British Columbia Ministry of Education and the Canadian Revenue Agency.
b. When and how do we obtain consent?
We obtain your consent prior to collecting, using or disclosing your personal information for any purpose. The form of consent is either express or implied and will largely depend on the sensitivity of the information and the reasonable expectation to privacy that you may have in the particular circumstance.
For example, consent is obtained when you submit your course registration form or provide your information when entering a contest or contact us form.
Specifically, collection of Registration Information such as Driver’s Licence information, Social Insurance Number, credit card or payment information is expressly consented to when submitting an application for a diploma course. However, rest assured that this information of a highly sensitive nature will never be shared with anyone other than the responsible government agencies that require disclosure.
c. Where do we store your personal information?
We store your personal information in our offices in Canada. When you contact us through the Site, we will maintain your contact information for our records unless and until you ask us to delete this information.
Our service providers may, from time to time, also hold your Personal Information in connection with purposes for which you provided your consent. Our service providers may store your information temporarily in the United States or Canada. We may keep a record of your Personal Information, correspondence or comments in a file specific to you.
d. How long will we use, disclose, or retain your Personal Information?
Your Personal Information will be used, disclosed, or retained for as long as necessary to fulfill the purposes for which it was collected and permitted or required by law. Generally, we do not disclose your personal information, and where we do, we will identify to whom and for what purposes the disclosure will be made and will obtain your consent to such disclosure. In any case, we only disclose your personal information as permitted or required by law.
We make reasonable security arrangements to protect your Personal Information against risks such as unauthorized access, collection, use, disclosure or disposal. We integrate these security measures into the design, application, and operation of the website. We take reasonable measures to evolve with the risks so that the integrity and confidentiality of your Personal Information and our systems are maintained.
e. How we will communicate with you.
Through our Site and various offline means, you may sign up or opt-in to receive communications from Mirage Spa. If you do not opt-in, We will not send you any communications, including promotional offers. Each communication sent to you by us contains an “unsubscribe” link or other unsubscribe mechanism, allowing you to opt-out at any time.
3. Disclosure of Personal Information
a. We use service providers (including our affiliates) to help us operate our Site, and to administer business activities on our behalf, such as sending emails, fulfilling orders, conducting contests and promotions. We may share your information with these third parties for those limited purposes. All of our service providers are required by contract to comply with our privacy standards to protect the privacy of your Personal Information, and to only handle your Personal Information for the purposes of the Site.
b. As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
c. Generally, you can opt out of targeted advertising by visiting:
- i. FACEBOOK – https://www.facebook.com/settings/?tab=ads
- ii. GOOGLE – https://www.google.com/settings/ads/anonymous
- iii. BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
- iv. Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
5. Notice for European Residents
- i. where we need Personal Information to perform a contract with you;
- ii. where the processing is in our legitimate interests;
- iii. where the processing is necessary for us to meet our applicable legal obligations; or
- iv. if we otherwise have your consent.
b. If you are a European resident, you have the right to:
- i. Request access to Personal Information about you.
- ii. Request correction of the personal information that we hold about you.
- iii. Request erasure of Personal Information about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- iv. Object to processing of Personal Information about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom.
- v. Request restriction of processing of Personal Information about you. You can ask us to suspend the processing of Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- vi. Request the transfer of Personal Information to you or to a third party. vii. Withdraw consent at any time where we are relying on consent to process Personal Information about you.
c. If you would like to exercise any of the rights listed under section 5(b), please contact us through the contact information below.
d. Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information. We encourage you to first reach out to us at Allison@tboventures.com, so we have the opportunity to address your concerns directly before you do.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at Allison@tboventures.com.