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Privacy Policy

 
 
 

We Are Committed to Respecting Your Privacy

This solution is administered by ELAM Ltée. (“We”).

We are committed to respecting your privacy and making sure that the personal information that we collect, use, and otherwise process in connection with your use of our website and/or the delivery of our services is kept secure and is processed in a transparent, lawful, and fair manner. For greater clarity, this privacy policy applies to all handling of personal information by ELAM Ltée to exclude our employees’ personal information, which is subject to a different internal policy.

This policy explains when and why we collect personal information about our users and students, how we use it, the conditions under which we may disclose it to others, and how we keep it secure.

Why do we collect information about you?

Personal data submitted on this website and/or the delivery of our services will be used for the purposes specified in this privacy policy:

  • enable the use of the services available on our website and its applications;
  • help our teachers place students in classes at the correct level;
  • process transactions (send statements, invoices and collect payments);
  • administer the website and its applications (improving your browsing experience by personalizing the website and its applications, including the selected language);
  • ensure your satisfaction concerning our services and make recommendations about the services that may be interesting to you;
  • send you general communications or transmit information that you specifically requested;
  • send you our newsletters and other marketing communications if you have agreed to receive such communications.
  • To comply with legal obligations.

We do not sell your information to third parties. We strictly use third parties as necessary to perform your services. These third parties are sub-processors that are subject to data processing agreements as to how they can process personal information on behalf of ELAM Ltd.

When do we collect information?

  • when you apply for our services or register as a new student, including to evaluate your fluency in a certain language;
  • when we evaluate your performance as a student at the end of the services;
  • when we must process and deliver our services, manage payments, fees;
  • when we create customized content for our classes based on your needs;
  • when you fill forms on our websites, including to contact us, such as via the messaging application available via on website;
  • when you contact us via e-mails and other means of communications;
  • when we administer and protect our business, this website and its applications (including troubleshooting, data analysis testing, system maintenance, support, reporting, and hosting of data);
  • when you make suggestions and recommendations.

Note that we may also receive your personal information from your employer as part of our corporate services.

What information do we collect about you?

ELAM Ltd. strives to apply the highest privacy standard to all its users and students, regardless of their geographical locations. In this context, ELAM Ltée has adapted the inclusive definition of “Personal Information” found under the General Data Protection Regulations enacted by the European Union (“GDPR”). For this Privacy Policy, personal information means any information about an individual from which that person can be identified or identifiable. Thus, we may collect, use, and otherwise process different personal data about you, which are grouped as follows:

  • personal identification data such as first name, last name, date of birth, employer, title, email, work telephone, and cellular phone;
  • financial and transactional data such as payment card details and services that you have purchased from us – note that in the case of corporate services, the financial and transactional data are typically those of the employer;
  • technical data about your computer or other devices you used to access our website or services such as internet protocol (IP) address, the date and time of your visit, the referral URL, the pages visited on the website, and information about your browser.

Under some legislation like the GDPR, some electronic information is considered personal information to the extent that it can identify you.

The website and its applications use cookies and other similar tracking technologies. Please read our Cookie Policy to learn more about the type of technology used, the type of information collected, why it is collected, how it is used and how you can manage your preferences regarding their use.

Do we share your information?

We will not share your information with any third parties for direct marketing. ELAM Ltd. doesn’t allow any add partners or affiliates to collect your personal data for their own purposes directly on our website. We do not sell your personal data to anyone.

However, our website contains some web applications run by third parties; this includes Formdesk and Zendesk. In addition, we use data processors who are third parties who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. Note that some of our teachers are hired on a subcontractor basis and are treated as the data processor.

In some circumstances, we are legally obliged to share information. For example, under a court order or cooperating with other supervisory authorities in handling complaints or investigations. We might also share information with other regulatory bodies. In any scenario, we’ll satisfy ourselves that we have a lawful basis on which to share the information and document our decision making and satisfy ourselves we have a legal basis on which to share the information. We will never share your information without first analyzing the request.

Where do we store your information?

The personal information that we collect via our website or for the performance of the services is stored through Microsoft Forms and SharePoint. Your personal information is stored and processed exclusively in the United States, Europe, and/or Canada.

How do we protect your information?

We will take reasonable physical, technical and organizational safeguards to make sure your data is safe with us. These measures are meant to protect your information against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use, or processing.

Cookie Policy

This website and its applications use ‘cookies’ and other technologies such as pixel tags and web beacons. Since some cookies include information that is considered personal under some laws, such as IP addresses and location, we treat such data with care by applying the right measures of protection.

What is a Cookie?

Cookies are small data text files that are sent from a server during a browsing session. Cookies are typically stored on your computer’s hard drive and are used by websites to simulate a continuous connection to that site. The use of cookies automatically identifies your browser whenever you interact with a site. A “web beacon,” also known as a tag, pixel tag, or clear GIF, is used to transmit information back to a web server. When we talk about “cookies” in this policy, we mean not just cookies but web beacons and similar technologies.

Browsers and devices have tools that allow you to disable cookies on sites and apps. If you disable cookies, you may not be able to access all the features of our services. We suggest that you keep our essential cookies (described below) active for a better user experience and help us keep improving and developing our products and services.

If you keep reading, you will learn about all the types of cookies we use and their specific functionalities.

Why do we use cookies?

Cookies are useful to allow our website and its applications to function to their full potential to enable specific functions. We do not use cookies to monitor your traffic or to analyze your actions.

What type of cookies do we use?

When you browse this website or private portal, different types of Cookies are set on your device.

Cookies can be installed by us or can be installed by third parties. Keep reading below to learn about third-party cookies.

ELAM Ltée uses both session cookies and persistent cookies. Session cookies are temporarily set on your device and disappear once you close your web browser window, but persistent cookies remain on your device for some time, which may vary from a few weeks to a few years.

ELAM Ltée uses Necessary Cookies, which help make a website usable by enabling basic functions like page navigation and access to secure website areas. The website cannot function properly without Necessary Cookies. We also use Preference Cookies, which enable our website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

Other types of cookies used by ELAM Ltd. included Statistic Cookies, which help us understand the traffic on our website. The information reporting through these cookies, such as Google Analytics, is anonymous and concern the traffic in general, not your personal usage.

Lastly, we used Marketing Cookies, which are described in the following section.

We may collect the following personal data through cookies: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed, or other actions taken on our sites and apps; time and date of those actions; country and language selected.

Can third parties access my cookies?

This website contains third-party cookies, such as Marketing Cookies used to track visitors across websites. These cookies intend to display relevant and engaging ads for the individual user and thereby more valuable for publishers and third-party advertisers. Especially, this website contains cookies from Facebook and Doubleclick. These are non-permanent cookies that last either for your session or for a period of 3 months before being erased from your device.

In addition, when using third-party applications on our website, such as Zendesk Chat (messaging application), you are subject to their privacy policy. Your devices may be exposed to additional cookies, including persistent cookies. Please click here to read Zendesk Chat’s Privacy Policy.

How do I manage my preference?

You may set your browser to block cookies, including those associated with our services. However, it is important to remember that certain website features may not function properly if cookies are disabled. Cookies enable you to take full advantage of some of the website’s best features, so we recommend that you keep them enabled.

You may also use the “help” function on the toolbar of your web browser to prevent your browser from accepting new Cookies, have your browser notify you when you receive new Cookies, and disable Cookies altogether.

Can we change this policy?

Yes, we strive to adapt this policy to new technologies, changes on the websites, or regulatory requirements. All updates will be posted on this page, and we will notify our users by e-mails and social media through a notification on our website and/or as required by applicable laws.

What can I do to control the processing of my personal information?

Various regulations allow you to exercise some rights regarding your personal information. Generally speaking, if you are a citizen of the European Union, you will typically have access to the rights outlined in the General Data Protection Regulation regarding the personal information that we hold about you.

Furthermore, unless you are subject to an exemption, you have the following rights concerning your personal data:

  • right to access, correct and limit the processing of your personal data;
  • right to have your personal data erased where it is no longer necessary for ELAM Ltd. to retain such data;
  • right to withdraw your consent to data processing at any time unless required for legitimate or legal reasons;
  • right to change or withdraw your consent to data processing and marketing communications;
  • right to complain about a supervisory authority.

Please note that ELAM Ltd. does not control the means and purposes of processing personal information regarding data subjects involved in language classes through a third party, like an employer. If this applies to you, please contact this third party directly to exercise your rights.

Do you have more questions?

Do not hesitate to contact our Chief Privacy Officer, Paule Grenier by email at privacy@elam.ca or by telephone at 877-395-3526 should you have any questions concerning your rights and better understand how we protect your personal information.