At Erna Stassen Consulting Ltd., we are committed to providing our clients, customers, and subscribers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers, and subscribers, protecting their personal information is one of our highest priorities.
While we have always respected our clients, customers, and subscribers privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our clients, customers, and subscribers 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 Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients, customers, and subscribers personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients, customers, and subscribers personal information and allowing clients, customers, and subscribers to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Erna Stassen Consulting Ltd. and its subsidiaries, Erna Stassen Coaching, Living a Self-Empowered Life, Revolution to Empowered-Self-Care.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Erna Stassen Consulting Ltd.
Personal Information –means information about an identifiable E.g., including name, email address, age, home address and phone number. Personal information does not include contact information (described below).
Contact information – means 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 – means the individual designated responsibility for ensuring that Erna Stassen Consulting Ltd. complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the clients, customers, and subscribers 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 only collect clients, customers, and subscribers information that is necessary to fulfill the following purposes:
To deliver requested products and services. To verify identity we may collect name, email address, and phone number or Skype name.
To process a subscription. To verify identity we may collect name, and email address.
To provide coaching services. To verify identity we may collect name, email address, home address, profession, birth date and phone number and or Skype address.
To enroll the client in a program. To verify identity we may collect name, email address.
To ensure a high standard of service to our clients, customers, and subscribers
To collect and process payments. To verify identity we may collect name, email address, home address and phone number.
Policy 2 – Consent
2.1 We will obtain client, customer, subscriber consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided in writing, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer, subscriber voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client, customer, subscriber is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client, customer, subscriber does not opt-out.
2.4 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), client, customer, subscriber can withhold or withdraw their consent for Erna Stassen Consulting Ltd. to use their personal information in certain ways. A client’s, customer’s, subscriber’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 client, customer, subscriber in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, customer’s, subscriber’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);
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
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client, customer, subscriber 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 client, customer, member surveys in order to enhance the provision of our services;
To contact our [clients, customers, members] directly about products and services that may be of interest.
3.2 We will not use or disclose client, customer, subscriber personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client, customer, subscriber lists or personal information to other parties [unless we have consent to do so].
Policy 4 – Retaining Personal Information
4.1 If we use client, customer, subscriber personal information to make a decision that directly affects the client, customer, subscriber, we will retain that personal information for at least one year so that the client, customer, subscriber has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client, customer, subscriber personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client, customer, subscriber personal information is accurate and complete where it may be used to make a decision about client, customer, subscribers or disclosed to another organization.
5.2 Client, customer, subscriber 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 client, customer, subscribers correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client, customer, subscriber 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 client, customer, subscriber personal information is appropriately protected:
The use of locked filing cabinets; the use of user IDs, passwords.
6.3 We will use appropriate security measures when destroying client, customer, subscriber’s personal information such as shredding documents, 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.
Policy 7 – Providing client, customer, subscriber Access to Personal Information
7.1 Clients, customers, subscribers have a right to access their personal information, subject to limited exceptions.
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 client, customer, subscriber 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 client, customer, subscriber of the cost and request further direction from the client, customer, subscriber 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 client, customer, subscriber in writing, providing the reasons for refusal and the recourse available to the client, customer, subscriber.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Erna Stassen Consulting Ltd. compliance with this policy and the Personal Information Protection Act.
8. Clients, customers, subscribers should direct any complaints, concerns or questions regarding Erna Stassen Consulting Ltd. compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer, subscriber may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Erna Stassen Consulting Ltd. Privacy Officer or designated individual:
Erna Stassen Consulting Ltd. (the “Company”) respects the privacy concerns of the users of its website, ernastassen.mykajabi.com and the services provided therein (the “Site”). The Company thus provides this privacy statement to explain what information is gathered during a visit to the Site and how such information may be used.
Use of Information: As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of the Company’s internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.
The Site’s various mailing lists, downloads, special offers, contests, registration forms, and surveys may request that you give us contact information such as your name, mailing and/or e-mail address, demographic information such as your age and gender, and personal preference information such as your preferred software and interests. Information submitted at the time of submission will be used by the Company only as necessary for our legitimate business interests, including without limitation the improvement of our products, services and the contents of the Site. The Company may also share such information with our business and promotional partners to further those interests. Personally identifiable information is never sold or leased to any third parties. With your permission, we may use your contact information to send you information about our company and products. You may always opt-out of receiving future mailings as provided below. The Company does not store any credit card information it may receive in regard to a specific transaction and/or billing arrangement except as necessary to complete and satisfy its rights and obligations with regard to such transaction, billing arrangement, and/or as otherwise authorized by a user.
The Company may disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with the Company’s rights or property, other users of the Site, or anyone else that could be harmed by such activities.
Children Age 13 and Under: The Company recognizes the special obligation to protect personally identifiable information obtained from children age 13 and under. AS SUCH, IF YOU ARE 13 YEARS OLD OR YOUNGER, THE COMPANY REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO THE COMPANY. If the Company discovers that a child age 13 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.
The Company nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:
Company uses the following cookies on the Site:
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Malware/Spyware/Viruses: Neither the Company nor the Site knowingly permit the use of malware, spyware, viruses, and/or other similar types of software.
Bulletin Boards and Chat Areas: Guests of the Site are solely responsible for the content of messages they post on the Company’s forums, such as chat rooms and bulletin boards. Users should be aware that when they voluntarily disclose personal information (e.g., username, e-mail address, phone number) on the bulletin boards or in the chat areas, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features. Choice/Opt-Out: The Site may provide you the opportunity to opt-in to receive communications from us at the point where we request information about you. You always have the option of removing your name from any e-mail list in order to discontinue any such future communications. In order to ensure immediate removal from any list, please follow the specific instructions set forth within the communications you receive from the Company which you no longer wish to receive. If you are unsuccessful in completing the instructions specified in any such communication, please e-mail us at [email protected], including a copy of the undesired email attached to the request, and state you wish to be removed from the mailing list.
Contact Information for Complaints or Concerns: If you have any complaints or concerns about the Company or about this privacy statement, please contact:
Via email: [email protected]
Information provided by you via general e-mail inquiries to the Company such as your e-mail address is used only to respond to your inquiries in the ordinary course of business, and is never shared with third parties.
Security: Security for all personally identifiable information is extremely important to us. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, The Company cannot ensure or warrant the security of any information you transmit via the internet. By transmitting any such information to the Company, you accept that you do so at your own risk.
Last Updated:March 18, 2016
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