1. Privacy Officer
2. Why is this Personal Information Collected (Business Purposes)?
Grow Vantage™ collects and uses personal information for the following Identified Purposes:
- To understand and fulfill client needs or requests for Grow Vantage™ products and personalized services; and to refer business to Grow Vantage™ participants;
- To develop client accounts for our clients, provide access to our website and to maintain the integrity of the website;
- To allow access to private/member only areas of the Grow Vantage™ website, directory listings, and the announcement mechanism which allows our clients to advertise their services;
- To provide services and products for our clients, including transmitting training information, training class schedules or materials;
- To confirm the Identity of specific clients (to avoid breaching the privacy of other clients)
- To communicate with clients and site visitors, when necessary, and to inform clients of upgrades, as well as marketing offers for other products and services available from Grow Vantage™, its affiliates and third parties;
- To bill accounts and maintain payment records; and to collect payment, or unpaid accounts if necessary;
- To comply with any applicable law, regulation, legal process or government request;
- To respond to a legitimate claim, or to address our reasonable belief, that you are violating the rights of any third party or any of the agreements or policies that govern your use of the Grow Vantage™ site or any product or service;
- To protect the services, products or rights of Grow Vantage™, including but not limited to the security or integrity of the Grow Vantage™ site; and
- To identify and resolve technical problems concerning the Grow Vantage™ site, products and services.
- To analyse client activity in aggregate form (i.e., not individually attributable to you) for its business analysis, operational, marketing and other promotional purposes; and to provide general statistics to organizations that track aggregate information regarding entrepreneurs.
When you visit the Grow Vantage™ web site, a cookie may be placed on your computer or the cookie may be read if you have visited the Grow Vantage™ site previously. If you choose to not have your browser accept cookies or pixels from the Grow Vantage™ web site, or social media sites, you may not be able to view all the text on the screens, or to experience a personalised visit, or to subscribe to certain service and product offerings on the Grow Vantage™ site.
3. Consent for Collection, Use and Disclosure of Information
Consent is obtained from each client by giving them a form to be signed that explains the use of material, requests consent to share our clients’ business information, the set-up of client accounts, access to advertising mechanisms. If a new use of client data is contemplated, Grow Vantage™ will seek approval for that use.
The consent statement explains that information permits business referral activities to Patricia Dent, owner, Grow Vantage™, Inc., other Grow Vantage™ participants, and potential clients or associates for mutual benefit. This information is also used to create a membership profile, a web profile and establish email communications related to the Grow Vantage™ program.
Registration forms also outline the information that Grow Vantage™ uses to set up profiles on the public directory, and contact emails for Grow Vantage™ information. Further updates to client information are the responsibility of the client, and they are given instructions to make updates or changes to their information. They may also inform Grow Vantage™ about changes to their personal information by email or phone to receive assistance in managing the updating process. When made aware of these requests, we commit to using the new or updated personal information received.
4. Limiting the Collection of Personal Information
Grow Vantage™ limits its collection of personal information to only that information which is necessary for the Identified Purposes. Grow Vantage™ does not direct its site to, nor does it knowingly collect any personal information from children under the age of thirteen.
What kind of information does Grow Vantage™ collect?
For clients: Grow Vantage™ collects information to fulfill the business purposes outlined above, at the time of your registration, certain “personal information” (information that personally identifies you) including but not limited to the following:
- Contact information (both business and home information, including name, email addresses, home and business addresses, phone numbers)
- Financial information, including credit card information to establish recurring payments for Grow Vantage™, for those who choose this option and while payments are due to Grow Vantage™. This information is kept by approval on physical forms during the period that payments are due to Grow Vantage™, and then shredded.
- Age categories
- Computer hardware or software information through cookies (e.g., IP address, operating system, browser type, domain name, URL, access times, and referring web site addresses).
- Business information in conjunction with business coaching activities
- Information may be made available to the following third parties, all of which have privacy policies in place. They include:
- The Grow Vantage™ accountant and bookkeeper (financial information for the purposes of tax planning and reimbursement)
- QuickBooks software and PayPal software (online)
- Collection agencies (in the case of delinquent accounts)
- Email Marketing services (currently Aweber)
- Web firms which support the Grow Vantage™ Website or performs digital marketing activities (Piggybank Marketing) and Kajabi (online teaching and sales platform)
- Virtual Assistants (from time to time to monitor announcements, send referral letters, past due collections, and miscellaneous administrative activities
- 3rd party backup software to ensure the security of Grow Vantage™ data and files (Backblaze)
Clients and non-clients who sign-on to receive email communications (without necessarily becoming clients of Grow Vantage™), provide their name and email address. This information is stored on our Aweber account and the Grow Vantage™ website.
5. Limiting Use, Disclosure and Retention
How will this information be processed and stored?
Your information may be stored and processed in the Canada or the United States, or in any other country in which Grow Vantage™ or its affiliates, subsidiaries, suppliers or agents maintain facilities. By using this web site, you consent to any such possible transfer of information outside of your country.
- Information is primarily managed internally.
- When consent is obtained from each client, their email is added to our email list, a membership profile is added for each client and a web profile is established on the Grow Vantage™ website.
- Client contact information is shared with the other members of your GV group and instructors (based on signed agreement within client contracts).
- Training notes and communications regarding the program are sent by the email address provided to Grow Vantage™. The information is also used to understand client demographics and from time to time, to provide non-specific statistical information to organizations who track entrepreneurial statistics.
- If Grow Vantage™ hires other companies to provide some products or services on our behalf, we will only provide those companies or individuals the personal information they need for the Identified Purposes within their scope of work, and we will limit their rights to use and further disclose your personal information as appropriate in the course of their work for us.
- Information that Grow Vantage™ gathers is retained in web-based software associated with the Grow Vantage™ website, in an Aweber account for email services, in a Kajabi account that manages online sales and teaching platform, QuickBooks and PayPal software to manage finances and in an excel-based database or reports.
- Financial data is stored on a main stand-alone server owned by Grow Vantage™, which is not connected to the Internet and which is backed up each time it is accessed, to a USB key and a second back up to an external hard drive (also not attached to the Internet). Information is also stored on password protected computers owned by individuals who are participants in the company or are contracted to the company, to provide support. Hard copies of reports may be retained in a locked filing cabinet in the Grow Vantage™ (home-based) office on the Grow Vantage™ Google business account (in Google docs).Backups of Grow Vantage™ computers are made on a continuous basis to Backblaze (in the cloud).
Will this information be disclosed?
Grow Vantage™ does not sell or rent your personal information to anyone. Grow Vantage™ does not disclose your personal information to anyone who falls outside the umbrella of the Identified purposes, except in limited situations (e.g. in accordance with subsection 8 (2) of the Privacy Act), for example in the following cases:
- To someone you have designated to act as your agent, for one or more of the Identified Purposes (listed above);
- To Grow Vantage™ employees, independent contractors, subsidiaries, affiliates, consultants, business associates, service providers, suppliers and agents, who provide services to Grow Vantage™;
- Someone our clients have designated to act as their agent, for one or more of the Identified Purposes
- If Grow Vantage™ has reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with Grow Vantage’s™ rights or property, other users of the Grow Vantage™ web site, products or services, or anyone else that could be harmed by such activities; and
- To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
- In addition, as Grow Vantage™ continues to develop its business, we or our affiliates or partners may sell or buy other businesses or entities, or we may merge with another company. In such transactions, personal information may be one of the transferred business assets.
How long will the information be retained?
Grow Vantage™ member information will be used in relation to the identified purposes below. After your account becomes inactive (that is, if you request to be removed from our database), Grow Vantage™ will keep your personal information in its private archives. Your information will then be used only as necessary for tax reasons or to prove that Grow Vantage™ is compliant with any applicable law.
- A public directory listing will be deleted if a member advises that their directory listing should be removed because they no longer wish to be associated with Grow Vantage™, or their business has been closed.
- When a member has unsubscribed from the Grow Vantage™ email list, their email address is maintained in our 3rd party database under the unsubscribed category (and in our website database as an unsubscribed email address) to ensure adherence to legal statutes.
- Products or services may be removed from a client as a result of an account that is not in good standing (and until payment is made and according to CRA guidelines).
- Financial records are retained according to CRA guidelines.
- Credit card information is maintained until outstanding payments to Grow Vantage™ are completed, resulting in a zero account balance.
How will information be disposed of?
- Once accounts have achieved a zero balance, credit card information is shredded.
- Grow Vantage™ account records are maintained to satisfy CRA requirements, and then will be shredded.
- Grow Vantage™ databases will be archived and stored in a secure location, since Grow Vantage™ may offer clients long-term advertising services on their website for an extended time past their active participation as paid clients
6. Ensure the Accuracy of Personal Information
The Chief Privacy Officer is responsible to ensure the information collected is as accurate as can be at the time of collection. Grow Vantage™ ensures the accuracy of personal information by asking their clients to fill in and complete their own information and registration forms. Grow Vantage™ will use reasonable efforts to keep client personal information accurate for the Identified Purposes, and to minimize the possibility of making inappropriate client decisions based on such information.
Clients are responsible for informing Grow Vantage™ about changes to their personal information. They can do this by sending an email to email@example.com or using the contact form on the website. Grow Vantage™ will use new or updated personal information it receives from clients to update its own records.
7. How will the information be safeguarded?
Electronic databases, servers and individual computers are password protected. All computer hardware has firewall and virus protection in place and data is backed up using Backblaze software which is password-protected, and which has the same safeguards in place.
The filing cabinet housing personal information in the Grow Vantage™ office is locked when not in use. Access is only granted on a need-to-know basis to those individuals who are under contract to Grow Vantage™ to provide specific services. No unauthorized parties are able to access this information.
8. Openness, and
9. Individual Access
Requests for access, updating or withdrawal of information
Grow Vantage™ will afford clients and vendors a reasonable opportunity to review the personal information in their file. Please direct any requests for access to your information in writing to Patricia Dent, firstname.lastname@example.org or by mail at Suite Success at ESS Direct, Suite 5, 411 Huronia Road, Barrie, ON L4N 9B3.
- Please allow 14 days for a response to your request.
- Your information will be provided to you as quickly as possible (but no later than 30 days from the date of your request), as long as that information may be legally copied to the person making the inquiry.
- If Grow Vantage™ is not able to provide access to some aspect of a client’s personal information, it will provide reasons for denying access such as (see legal restrictions and examples below):
- That the information relates to a breach of an agreement or a contravention of law
- Its disclosure could reasonably be expected to threaten the life or security of another individual.
In terms of mandatory exceptions, organizations must refuse an individual access to personal information:
- If it would reveal personal information about another individual unless there is consent or a life-threatening situation. I have a hard time imagining something like this because records are usually individual, unless you are involved in a law suit; or
- If an individual requests that he or she be informed of information disclosed to a government institution in certain specified cases, or for access to the information itself, and the government institution objects to the institution complying with the access request. In such cases, your organization must refuse the request and notify the Privacy Commissioner of Canada. As well, your organization cannot inform the individual of the disclosure to the government institution, that the institution was notified of the request, or that the Privacy Commissioner of Canada was notified of the refusal.
In terms of discretionary exceptions, organizations may refuse access to personal information if the information:
- Is protected by solicitor-client privilege
- Would reveal confidential commercial information, although if this information can be redacted, the organization must release the remaining information
- Would reasonably be expected to harm an individual’s life or security; although if this information can be redacted, the organization must release the remaining information
- Was collected without the individual’s knowledge or consent to ensure its availability and accuracy, and the collection was required to investigate a breach of an agreement or violation of a federal or provincial law (the Privacy Commissioner of Canada must be notified)
- Was generated in the course of a formal dispute resolution process, or
- Was created for the purpose of making a disclosure under the Public Servants Disclosure Protection Actor a related investigation
10 Challenging Compliance: Recourse
Complaints about the organization
- Please direct any complaints about the Grow Vantage™ organization in writing to Patricia Dent, email@example.com
- Please allow 14 days for a response to your request.
- To find resolution to a complaint, first approach the Grow Vantage™ privacy officer. Should that prove unsatisfactory, individuals can contact the Privacy Commissioner of Canada:
Daniel Therrien, 112 Kent St., Ottawa, ON K1A 1H3.
Clients have the right to request that information is removed that is no longer accurate or complete and information be amended as appropriate, by contacting Patricia Dent as described above, who will promptly correct such personal information.
Any challenges an individual wishes to make to the organization’s compliance with the above principles in this policy should be addressed to Patricia Dent, the Chief Privacy Officer at the above contacts, in writing.