Privacy policy

1. Scope and Application

This Policy applies whenever you interact with us, either through our website (accessible through the following domain: www.fairchancelearning.com), our mobile app, our social media pages, our service providers, via phone calls, or if you communicate with us by email or sign up to receive promotional or other material.

This Policy describes our policies and practices with respect to the collection, use and disclosure of personal information and the measures taken to ensure its continued protection. We also describe the rights and choices you have regarding your personal information.

By using our services and interacting with us, you provide consent to the collection, use and disclosure of personal information as set out in this Policy. In some cases, consent may be “implied”, i.e., your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information. We will generally obtain consent if and when it is required to use your personal information for a new purpose or for a purpose other than those identified in this Policy, in compliance with applicable laws.

2. What is “personal information”?

In this Policy, “personal information” refers to any information that could be used alone or in combination with other information to identify an individual. This may include, for example, your name, contact information, home address, email address and education information. It may also include more technical information, such as your IP address, browser settings and device ID, but only when this information can identify you as an individual. Information that is anonymized is not considered personal information.

3. What categories of personal information do we collect?

We limit the collection of personal information to what is necessary to fulfill the purposes identified in this Policy.

We may collect the following personal information about you depending on your interactions with Fair Chance Learning (for instance, if you are a learner, a website visitor, mobile app user or reach out to us on social media):

• Identifiers, such as your full name, email address, mailing address, telephone number, date of birth, social insurance number and other information you provide to us when you apply for a Fair Chance Learning program or contact us.
• Browsing activity, when you visit our website. This information is collected via automated means, such as cookies, web beacons and similar technologies, and may include your IP address, device ID, browser type, data about the web pages you visited on our website, your language preferences, email bounce backs and click-throughs. To learn more about how we collect and use this type of information, see “How do we collect your personal information?” below.
• Professional or education-related information, which may include some of the information described above, as well as your education and employment history and any additional information you provide when you apply for a Fair Chance Learning program or contact us.
• Any other information you provide to us, such as when you contact us by email, by phone, in person or through social media.

4. How do we collect your personal information?

We collect personal information in a variety of ways, including directly or indirectly from you, or automatically through our website, mobile application.

A. Directly From You

We may collect personal information directly from you. For example, when you:

• Agreements and Forms: Apply for a Fair Chance Learning program, including when you sign required applications, device loan agreements, learner agreements, participant registrations and media release forms.
• Registrations: Subscribe to our newsletters or other commercial electronic communications.
• General Contact: Contact, correspond or otherwise communicate with us, including when you contact us with an inquiry, report a problem with or interact with different functions of our website or mobile application, such as their chat functions, or when you message us on or comment about our content on social media.

If you give us the personal information of another individual, then you must take all measures, including obtaining the individual’s valid consent, to ensure that you have the lawful right to collect and disclose the information to us and for us to collect, use, disclose and retain the personal information as explained in this Policy.

B. Indirectly From You Third Parties

We may collect your personal information from other persons or organizations you authorize to provide the information to us, including as follows:

• Referring Agencies and Ministry of Labour, Immigration, Training and Skills Development: We may collect basic identifying information (e.g. your name, email address, phone number, address, age, eligibility to work in Ontario, employment status) from third-party agencies and the Ministry of Labour if they refer you to our programs so we can identify you and verify your eligibility when you apply for our programs.
• IT Service Providers: We may collect information (e.g. your name, email address, mailing address and phone number) from our IT service providers if you apply through them to loan Fair Chance Learning devices.
• Other persons and organizations that engage with our programs or services on your behalf or for your use.

C. Automatically Through our Website and Mobile Application

Fair Chance Learning may collect technical information (e.g. your IP address, browser type and device ID) and information about your device and browser (e.g. page views and clickstream data) when you visit our website or mobile application, using technologies, such as cookies. Some of these technologies may be operated by third parties. This information supports the functioning of our website and mobile application and helps us understand how you navigate and use our website or mobile application. It also helps enhance our website’s and mobile application’s design, functionality, and optimizing our marketing efforts.

We currently use the following types of cookies on our website and mobile application:

• Strictly necessary cookies: these cookies are essential to allow you to fully use our website and its full features. These cookies do not gather information about you that could be used for marketing. These cookies cannot be turned off as they are essential for enabling the basic functionalities of the website.
• Functional cookies: these cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features. They allow the website to remember your language preferences.
• Analytics cookies: these cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.

5. How do we use your personal information?

We may use your personal information: for our general business and legal compliance purposes relating to or arising from our relationship with and your use of our programs or services, to provide you with personalized information about our programs and services and other information we consider might be of interest to you, for additional specific purposes you consent to and as otherwise permitted or required by law. For example, we may use your personal information:

• for general business and legal compliance purposes, such as providing or delivering a program or service requested; confirming your eligibility or suitability for a program; managing our business, including our website and mobile application; responding to your inquiries; meeting our contractual, legal and regulatory obligations as well as for purposes relating to information, system or network security.
• to provide you with customized information and offers regarding our programs and services and other programs and services that might be of interest to you.
• such as technical information collected by cookies to enhance our website’s design, functionality, and optimize our marketing efforts, subject to your privacy choices as explained under “What are your privacy choices?” below.

6. When do we share your personal information with other organizations?

We may share your personal information with our business partners and our service providers (companies that carry out activities on our behalf), and in the context of a sale or transfer of our business or similar transaction. We may also share your personal information with your consent or in accordance with applicable law.

A. Business Partners

We may share your personal information with other organizations and business partners with whom we work or that use our programs, to the extent permitted by law. For example, we share the information in the Skills Development Fund Training Stream (SDF-TS) Participant Registration form with the Ministry for the purposes of providing our programs and services, including to confirm the learners registered with Fair Chance Learning and so the Ministry can keep accurate records about our programs and services. Please visit the Ministry’s website and the Government of Ontario’s Privacy Statement for more information about how the Ministry handles your personal information. We may also share your name and engagement status in our programs or services with third-party referring agencies so those agencies can keep accurate records of successful referrals.

B. Service Providers

We may share personal information with our agents, vendors or other organizations that provide services on our behalf, for the purposes set out in this Policy. These service providers help us operate and manage our website, information systems, infrastructure and marketing. They provide services to us, such as background checks, administering device loans, email communications, mail delivery, data hosting and analytics services (e.g. analyzing usage of our website).

When Fair Chance Learning shares personal information with our service providers, we ensure by contractual means that the shared personal information is used only for the purposes for which the service provider is retained and is protected to the same degree as it is when in our possession. Our service providers may be located around the world, as further detailed in the “Cross-border transfers of personal information” section.

C. Sale or Transfer of Our Business or Other Transaction

We may decide to sell or transfer all or part of our business to a third party, merge with another entity, secure our assets or proceed with any other financing or other strategic capital transactions (including insolvency or bankruptcy proceedings), restructuring, share sale or other change in corporate control. We may share your personal information when required for the purposes of such a transaction in compliance with applicable laws.

D. Other permitted reasons

We may share your personal information when permitted or required by applicable law, for instance:

• With governmental authorities, law enforcement and courts when compelled by law; and
• For the purposes of detecting or suppressing fraud or criminal activity, protecting our assets and interests, conducting an internal or external investigation into any actual or suspected illegal activity or managing, defending or settling any actual or potential loss in connection with the foregoing.

7. What are your privacy choices?

You have choices about the way Fair Chance Learning handles your personal information.

A. Changing Your Cookie Preferences

Most browsers let you remove or stop accepting cookies from the websites you visit, including ours. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change the settings. If you do not accept cookies, however, you may not be able to use all functionalities of our website or our website might not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

B. Your mobile device settings

Your mobile device settings may allow you to choose the way that we collect and use some of your personal information (e.g., your location) or communicate with you. Please refer to your device settings or user manual to learn about those settings.

C. Restricting Collection, Use and Disclosure of Your Personal Information

You may withdraw your consent to the collection, use and disclosure of personal information in accordance with this Policy at any time upon reasonable notice to Fair Chance Learning in writing, subject to legal or contractual restrictions. To withdraw your consent, please contact us in writing using the relevant contact information listed in the “Contact Us” section below.

If you withdraw your consent to our collection, use or disclosure of your personal information, it may affect our ability to deliver our programs or services to you. In certain situations, we may be entitled to retain your personal information to comply with applicable legal requirements, to establish, exercise or defend our rights or legal claims, and for other legitimate business purposes described under “How do we use your personal information?”

8. How do we protect your personal information?

Fair Chance Learning maintains appropriate policies and practices aimed at safeguarding your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:

• Governance and Accountability: we maintain a Privacy Framework that defines the roles and responsibilities of all Fair Chance Learning personnel and ensures compliance with applicable privacy laws and we have a designated Privacy Officer who oversees adherence to privacy obligations and acts as the primary contact for inquiries or complaints.
• Policies and Access Controls: we maintain internal policies and procedures that restrict access to personal information strictly on a “need-to-know” basis and require Fair Chance Learning personnel to sign confidentiality agreements and comply with all privacy and security protocols outlined in Fair Chance Learning Employee Handbook and related agreements.
• Technical and Organisational Safeguards: we implement layered security measures, including (i) encryption for data in transit and at rest, (ii) firewalls, antivirus software, and password protection and for all systems, to protect personal information collected, used, or stored in electronic format, as well as (iii) secure storage and isolation of backup archives and (iv) monitoring an limiting systems access to authorised users only.
• Training and Awareness: all Fair Chance Learning personnel undergo mandatory privacy and cybersecurity training to ensure awareness of obligations and best practices.
• Complaint Handling: we maintain documented procedures for receiving, investigating, and responding to complaints or inquiries regarding our information handling practices.
• Third-Party Management: our service providers entrusted with personal information must comply with contractual provisions requiring adequate privacy protections and security standards.
• Retention and Destruction: we retain personal information only as long as necessary for the purposes outlined in this Policy or as required by law. When no longer needed, information is securely destroyed or anonymized.

Our goal is to prevent unauthorized access, loss, misuse, sharing or alteration of personal information in our possession. We also use these safeguards when we dispose of or destroy your personal information.

9. How long do we keep your personal information?

We retain your personal information for as long as necessary to achieve the purposes for which the information was collected as set out or referenced in this Policy, to comply with our legal obligations, and to enforce or protect our legal rights, or for a longer period required or permitted by applicable law. We will then delete or securely anonymize your personal information, or anonymize the information to use it for statistical and analytical purposes, in accordance with applicable law.

10. Cross-border Transfers of Personal Information

Fair Chance Learning is based in Canada. Some of our service providers may process, store or otherwise transfer your personal information outside of the country where we are located or where you reside, including in Canada and the United States. As a result, when your personal information is stored or processed in another jurisdiction, it may be accessible to law enforcement and national security authorities of those jurisdictions. We take steps to ensure that your personal information receives a comparable level of protection wherever it is processed.

11. Accessing and Correcting Your Personal Information

You may be entitled to access your personal information and request the correction information that is inaccurate, incomplete or no longer accurate, subject to limited exceptions set out in applicable laws. Depending on the jurisdiction where you reside, you may also be entitled to request the correction of your personal information if our collection, disclosure or retention of such information is not authorized by law.

To exercise your rights, please contact us in writing using the relevant contact information listed in the “Contact Us” section below.

12. Changes to the Policy

We may make changes to this Policy from time to time at our sole discretion. Any changes we make will be effective when we post the revised policy on our website. We will provide additional notice of changes to this Policy, as required by law. By continuing to interact with us after the modified version of the Policy has been posted, you are accepting the changes to the Policy, subject to any additional requirements that may apply. It is your responsibility to ensure that you read, understand and accept the latest version of the Policy. The “Effective Date” at the top of this Policy indicates when it was last updated.

You consent to our sending you emails (to the email addresses you provide to us) regarding this Policy and related matters and as otherwise permitted by applicable law.

13. Contact Us

If you have any questions or complaints about how we handle your personal information, please contact our Privacy Officer at privacy@fairchancelearning.com.