Last Revision: March, 2015
Contact Person for Privacy and Personal Information Queries and Concerns:
The Privacy Coordinator at Green Lotus is accountable for Green Lotus’ policies and practices, with respect to the management of personal information, and is the individual to whom your complaints and inquires can be forwarded.
1 Yonge Street, Suite 1801
Email: Bassem (at) greenlotus.ca
How We Collect and Use Your Information:
The information that Green Lotus collects about you can be classified as Personal Information and Anonymous Information. Personal Information refers to information that identifies you as a person (e.g. your name, postal address, phone number, email address, payment details). Personal Information will also include “personal information” as that term is defined in the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). Anonymous Information refers to information that does not identify a specific individual.
In order to effectively deliver those services to you, it is necessary to collect, use and disclose certain information from you, including Personal Information. We collect your email address when you register in a Green Lotus Service. If you (a) subscribe to a service plans in the Green Lotus SEO Tools, or (b) register for a Green Lotus Course, or (c) register for a Green Lotus Event, or (d) request a meeting via the Green Lotus website, we may also collect such information as your name, postal address, phone number, credit card and other billing information required for payment, as well as your IP address(es).
Every time you visit the websites, Green Lotus collects certain technical information from your visit via ‘cookies’ a small data file that is stored on a user’s computer to enable the Service to recognize a user that previously used the Service. This includes the pages that were visited and returned to, the time spent on the website by a visitor, the operating system, the referring site and any keywords used to find the website or service on search engines. This information does not contain any reference to your Personal Information. This information can only be accessed by Green Lotus and can be used with the sole purposes of tracking visits, analysis of aggregate data, marketing, improving user experience, quality of service, content and layout of the website.
For greater clarity, Green Lotus does reserve the right to perform statistical analyses of user behaviour and characteristics, in order to measure interest in and use of the various sections of its sites so as to improve design and navigation and to gather marketing information. Only Anonymous Information will be used for this purpose.
How We Share Your Information:
Privacy of our users is very important for Green Lotus. We shall not sell or rent your Personal Information to any third party. We shall share your Personal Information with the third parties only if such information is required to provide you with specific services, or at your request, and only that Personal Information which you permit to be so disclosed.
Green Lotus may permit select third parties to access specific information if they are contractually bound to a Green Lotus Event (e.g. event organizers, sponsors, partner charity). Authorized third parties may contact Event Registrants and Event Attendees by electronic means only, and will not automatically enroll registrants/attendees in any mailing list without the necessary consent required under Canadian Anti-SPAM Legislation (CASL).
Green Lotus may disclose Personal Information to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received, or otherwise required by law.
Email Communications from Green Lotus:
Green Lotus is committed to keeping your email address confidential. We shall use users email addresses exclusively to communicate Green Lotus information. Users can unsubscribe to Green Lotus emails at any time by selecting the ‘unsubscribe’ link provided in the footer of each email, or by writing to Bassem (at) GreenLotus.ca
How We Protect Your Information:
Once we received any information from you, Green Lotus shall make all reasonable effort to ensure the security of our systems. Please note that this is not a guarantee that unauthorized entry or use, hardware or software failure and other factors that may at any time compromise the security of user information, will not happen.
Photography and Filming of Green Lotus Events and Courses:
During Green Lotus Events and Courses any person in attendance may be photographed or filmed as part of the occasion, either as an individual or as a member of a group. An individual may also appear in a photograph or video inadvertently, in the background. If for any reason users/attendees do not wish to be filmed or photographed please inform on-site management staff.
If Green Lotus provides a blog or other similar public forum to which you may post reviews or information, you acknowledge and agree that any such information, including Personal Information, is thereafter public and not subject to this policy. Green Lotus will in no way be liable for or responsible for any third party’s collection, use or further disclosure of this information disclosed by you in this fashion.
Other PIPEDA-Related Privacy Provisions:
It is the policy of Green Lotus to control the collection, use, and disclosure of personal information in accordance with all requirements set out in PIPEDA and/or any applicable provincial legislation. In certain circumstances personal information may be collected, used, or disclosed without the knowledge and consent of the individual. Exemptions include, but are not limited to personal information gathered for:
- Legal, medical, or security reasons.
- Detection and prevention of fraud or for law enforcement.
- Journalistic, artistic or literary purposes if its use is confined to those purposes.
The following requirements shall be met by Green Lotus unless exempted by PIPEDA.
Green Lotus is responsible for personal information under its control and shall designate a Privacy Coordinator to be accountable for Green Lotus’s compliance with PIPEDA.
- Identifying Purposes
The purposes for which personal information is collected shall be identified by Green Lotus at or before the time the information is collected.
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, excepting only circumstances prescribed in PIPEDA.
- Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by Green Lotus and further consent must be obtained from an individual for any further collection of personal information.
- Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used, provided the individual has provided accurate, up-to-date and correct information to Green Lotus.
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
Green Lotus shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
- Individual Access
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
- Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for Green Lotus’s compliance.
Green Lotus Responsibility:
- All Green Lotus employees, who collect, maintain and/or use personal information, are responsible for insuring that the collection, use and disclosure of this information is carried out in accordance with this policy and relevant procedures.
- The Privacy Coordinator is responsible for supervising compliance with the legislation and for initiating procedures, guidelines and schedules that will be developed to effect this policy.
- The Privacy Coordinator is accountable for Green Lotus’s policies and practices, with respect to the management of personal information, and is the individual to whom complaints and inquiries can be forwarded.