Passion Inc. (“us”, “our” and “we”) thanks you for your interest in network.applytoeducation.com and such other products, services, features and content which we may offer from time to time (collectively, the “Services”).

We value the privacy of those who visit and use the Services (individually, “you” or collectively, “Users”). We take your privacy seriously and make it a priority to protect personal information that we obtain from and about our Users.

This privacy policy (“Privacy Policy”) describes:

1. what personal information we collect;
2. how and why your personal information is used;
3. to whom your personal information may be disclosed;
4. how we protect your personal information;
5. updating, accessing, and retaining your personal information, and
6. providing or withdrawing your consent to our collection, use or disclosure of your personal information.

By visiting and/or using the Services you expressly consent to the information handling practices described in this Privacy Policy. If you, as an external applicant not employed by an Employer using our Services, do not want your personal information to be used in the manner set forth in this Privacy Policy, please do not use the Services.

Our collection and use of information that identifies you, or by which your identity could, alone or in combination with other information, be deduced (such as your name, address, telephone number, e-mail address and credit card information) (“Personal Information”) is subject to the terms of this Privacy Policy. As we supply technology, hosting, and related services to employers (“Employers”) to help them post jobs, manage employment applications, schedule interviews, manage professional development, and fill daily supply openings on-line, Personal Information may be collected on behalf of Employers or for the benefit of Employers so that employees can use our Services within their organization.

1. What Personal Information We Collect
   
   
   1. Personal Information that you provide. From time to time, we may ask you to provide Personal Information. If you choose to provide such information, during registration or otherwise, you are giving us permission to use and store such information as provided in this Privacy Policy.
      
      
   2. Personal Information collected via cookies. When you use the Services we may use cookies to track information about your browser’s activities and to provide you with better services and features on the Services. The types of cookies we may use are “session cookies” and “persistent cookies”.
      
      1. Session cookies:
         
         
         1. Session cookies store information only for the length of time that you are connected to a website – they are not written onto your hard drive. Once you leave the website, they expire and are no longer active. We use session cookies to record certain information from your browser including your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, operating system and the dates and times that you use the Services. Additionally, we may record certain information regarding your use of features on the Services. Session cookies allow us to gather statistical data which provides insight into how we may improve our products and services and to identify your current session to our web server.
            
            
         2. Persistent cookies: Persistent cookies store information on your hard drive and can be re-read when you return to the site that placed them on your hard drive. We use persistent cookies to remember your preferences and to help block unauthorized attempts to access your Personal Information.
            
            
      2. Rejecting cookies: You may adjust your browser settings to notify you when a cookie is about to be sent or you may configure your browser to refuse cookies automatically. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Note that if you do not accept cookies you will not have access to certain services and features on the Services that rely on cookies for their functionality. For example, cookies are required to place an online order. Should you wish to block cookies through your browser, you may still purchase products through our Customer Service Department at 1-877-900-5627.
         
         
      3. Location information. We may collect and store information about your location, including IP addresses, if you enable your computer or mobile device to send us location information. This information can be used to deliver a more personalized experience that displays jobs close to where you live or may be used by employers to assist with managing recruitment and employment as described in more detail in Section 3a. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such information.
         
         
   3. Third-Party Web Beacons. We may also implement third-party content on the Services that uses “clear gifs”, “web beacons” or other similar techniques, which allow third-party content providers to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of content displayed on the Services.
      
      Web pages may contain web beacons that allow us to count users who have visited those pages. Web beacons are not used to access your personally identifiable information. They are a technique we use to compile statistics about the usage of our Services.
      
      Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides.
      
      
   4. Your relationship with us. We will collect information arising from your relationship with and through us and your use of the Services. For example, we will maintain a record of your transaction history. As well, when you send us an e-mail, speak with one of our telephone service representatives, or communicate with us through any other means, we may monitor, record and retain those communications for our mutual protection and in order to process your inquiries, respond to your requests and improve our services.
      
      
   5. Personal Information from Other Sources. We may also obtain Personal Information from third parties and sources other than the Services. For example, The Ontario College of Teachers (OCT) verifies and updates your qualifications if you supply an OCT # in your application. If we combine or associate information from other sources with Personal Information that we collect through our Services, we will treat the combined information as Personal Information in accordance with this Privacy Policy.
      
      
2. How and Why Your Personal Information is Used.
   
   
   1. To Serve you. We use the Personal Information you provide or that we collect in order to provide our products and services to you and to establish and enhance our relationship with you. We generally use the Personal Information you provide or that we collect to operate, maintain, enhance, and provide our products and services. The Services allow you to submit feedback. Should you choose to submit feedback, you consent to us contacting you by way of follow-up e-mail or phone call to discuss your feedback. Similarly, if you contact us with a question regarding your account, you give us permission to review your account to the extent necessary to answer your question. We do not review accounts of Users unless asked to do so by the User.
      
      
   2. Aggregate Information. We may generate non-identifying and aggregate profiles from the information you provide during registration for our products and services and through your use of our products and services. Non-identifying and aggregate profiles are used to improve the quality of our products and services and to develop new products and services. Aggregated non-personally identifying information may be shared with third parties.
      
      
   3. Marketing and Experience. We may use the Personal Information of external applicants to provide information about our features, services and other offerings that may be of interest to such persons. This information may be provided to you by mail, phone, and/or, email. We may also send information or offers to you on behalf of other businesses if you have given us permission to do so. We may share the Personal Information of external applicants with certain websites that we link to, to the extent that you click on such links, in order to enhance your experience in connection with the Services. We will not contact, on behalf of third parties, Employees who are required to have an account by their Employer to use our Services.
      
      
3. To Whom your Personal Information may be disclosed.
   
   Employers.
   1. We supply technology, hosting, and related services to employers to help them manage numerous aspects of employment and recruiting which may include posting jobs, managing employment applications, scheduling interviews, managing professional development, and tracking and filling daily supply openings on-line. Information, including Personal Information, supplied by an employee or applicant, collected as cookies or location information may become part of our database and may be accessed by the employer(s) selected by the applicant to view their application or by an employee’s employer. If you provide your Ontario College of Teachers membership number, you will be granting the College permission to provide your membership status and qualifications from the Public Register. This information will be uploaded to your application portfolio on the Services and will be visible to employers you apply to. If an application is stored in our database and set to 'not visible' by an applicant, the application can be used to apply for a job online but will not be searchable by employers through our application database. Applications stored in our database that are not set to ‘not visible' by the applicant will be searchable by employers that the applicant has selected through our application database and by employers whose job postings the applicant has applied to. Once an applicant has made their application visible through the Services, we cannot control how employers use the information. Applicants should check with specific employers’ privacy policies to ensure the use of information is limited to the purpose of obtaining employment. An applicant can remove their application from our searchable database at any time. However, employers who have access to our database may have retained a copy of the application in their own files or databases. We are not responsible for the retention, use or privacy of applications in these instances. When you select an employer to view your application or apply to a specific job posting you give permission to that employer to contact you and any references, school or faculty associates, or past or present employers named in your application.
      
      
   2. Our subsidiaries or affiliates. We may share your Personal Information with our subsidiaries or affiliates (the “Group”) for legal and regulatory purposes, to manage business risks, and to perform analytics. Personal information is not shared between divisions of Passion Inc for any purpose other than those described in our Privacy Policy.
      
      
   3. Suppliers. We may use other companies to provide services on our behalf. These companies will only be given the information needed to perform those services. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. In no case, will we grant any ownership or rights in any of our customer data to third parties.
      
      
   4. Merger or sale. In the event that we are acquired by or merged with a third-party entity, or if we sell a part of our business, we reserve the right to transfer or assign the Personal Information that we have collected from you as part of such merger, sale or other change of control to ensure the continuity of our business.
      
      
   5. Where required by law. We may disclose your Personal Information if we have a good faith belief that access, use, preservation or disclosure of such Personal Information is reasonably necessary to satisfy any applicable law, regulation, self-regulation, legal process or enforceable governmental request. When we provide Personal Information in response to a legal inquiry or order that we believe to be valid, we disclose only the Personal Information that is legally required.
      
      
   6. Protection of our interests. We may also disclose your Personal Information if we believe, in good faith, that it is appropriate or necessary to take precautions against liability; to help us collect a debt or enforce an obligation owed to us by you; to protect against fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of our products and services; or to protect the rights, property, or personal safety of our Users, employees or others.
      
      
   7. Consent. We may disclose your Personal Information where you have authorized us to do so. For example, if you have given us consent, we may share your Personal Information with business partners and other entities that are not affiliated with us who would like to send you information about their products and services. We do not share Personal Information with other third-party organizations for their marketing or promotional use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in and opt-out of.
      
      
4. How we protect your Personal Information.
   
   
   1. Security processes. We make commercially reasonable efforts to safeguard your Personal Information from loss or theft, unauthorized access, disclosure, duplication, use or modification through security measures appropriate to the sensitivity of the information. These measures include internal reviews of our data collection, storage and processing practices and security measures which include appropriate encryption and physical security measures to guard against unauthorized access to systems where we store Personal Information.
      
      
   2. Password. Your account and Personal Information is protected by a password for your privacy and security. Your password and other access codes are private and confidential - our employees cannot gain access to them and will not ask you to reveal them. It is your responsibility to use your best efforts to prevent unauthorized access to your account and Personal Information by selecting your password appropriately, and limiting unauthorized access to your computer, browser and mobile platform.
      
      
   3. Confidentiality obligations. We restrict access to your Personal Information to our employees, contractors and suppliers who need to know that information in order to process it on our behalf or to provide our products and services to you. Our employees, contractors and suppliers are bound by confidentiality obligations and may not use the information for any unauthorized purpose. Our employees may be subject to discipline, including termination and criminal prosecution, if they fail to meet their obligations described in this Privacy Policy. Our suppliers are required to protect your Personal Information in a manner that is consistent with this Privacy Policy.
      
      
5. Updating, Accessing, and Retaining your Personal Information.
   
   
   1. Updating and Accessing your Personal Information. If you setup an account through the Services, you may access, update, correct, or delete your profile information and preferences at any time by logging into your account.
      
      
   2. Retention of your Personal Information. We retain your Personal Information only as long as it is required for the reason(s) that it was collected. This length of time will vary depending on the product or service and the nature of the information and may extend beyond the end of your relationship with us. If you no longer wish to use the Services or if you are an Employer with whom we no longer provide Services to, upon request we will either destroy, delete, erase your Personal Information (or that of your employees) or convert it to an anonymous form, provided that if you have ever applied to an Employer(s) using our Services we may not be able to remove you from our database without the consent of the Employer.
      
      
6. Providing or withdrawing your consent.
   
   We will obtain your consent before collecting, using or disclosing your Personal Information, except where permitted or required by law. Depending on the situation and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be obtained verbally, electronically or in writing from you or your authorized representative (such as a legal guardian or attorney appointed pursuant to a power of attorney) for stated purpose(s). Implied consent may be obtained through your use or continued use of a product or service when the purpose(s) for collecting, using or disclosing your Personal Information is indicated by the relevant circumstances or follows logically from purposes identified in this Privacy Policy (such as when you approach us to obtain information or inquire about or purchase products or services from us). We will seek your consent before using your Personal Information for any purpose not previously identified and will limit the collection of your Personal Information to that which is necessary for the relevant purpose(s). We will not, as a condition of the supply of any of the Services, require you to consent to the collection, use or disclosure of Personal Information beyond that which is required to fulfill the purpose for which it is collected.
   
   In most cases you may refuse to provide your consent to our collection, use and/or disclosure of your Personal Information in accordance with this Privacy Policy. Note, however, that if you refuse to provide your consent or withdraw your consent, we may not be able to provide you with a particular product or service.
   
   You may withdraw your consent provided that: you provide reasonable notice; we are not legally required to collect, use or disclose your Personal Information; and withdrawing your consent does not impede our ability to fulfill our obligations to you. You may withdraw your consent by contacting us at info@applytoeducation.com or by calling us at 1 (877) 900-5627. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and record your choices.
   
   
7. Changes to this Privacy Policy
   
   We reserve the right to change this Privacy Policy at any time at our sole discretion. We will send an email notification to Employers if we have changed or updated this Privacy Policy and we will inform you of any such change by posting a new Privacy Policy on the Services and clearly marking the effective date of any such change to the Privacy Policy. Your continued use of the Services after the posting of changes constitutes your binding acceptance of such changes.
   
   
8. Third-Party Sites
   
   The Services may be linked to internet websites operated by other companies. You should consult the respective privacy policies of these third-party websites. Our Privacy Policy does not apply to, and we cannot control the activities of, such other third-party web sites. Please be aware that we do not warn you when you choose to follow a link through to another website from the Services. Examples of third party sites we link to are banner ads, Ontario College of Teachers, online testing providers, and any weblinks included in a job posting’s description.
   
   
9. International Users
   
   If you are a User outside of Canada, please note that we process your Personal Information on our servers in Ontario, Canada. In some cases, we process your Personal Information outside your own country. Therefore, Canadian federal and provincial governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in Canada. Your use of the Services or your submission of any Personal Information to us will constitute your consent to the transfer of your Personal Information outside of your home country, which may provide for different data protection rules than in your own country.
   
   
10. Our Commitment to Children's Privacy
    
    Protecting the privacy of young children is especially important to us. We do not knowingly collect any Personal Information of minors. If you are an individual, by accessing or using the Services, you represent and warrant that you are of legal age to form a binding contract. If we learn that Personal Information of minors has been inadvertently collected on the Services without parental or guardian consent, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that a minor for which you are responsible has registered an account with the Services without your consent, then you may alert us at info@applytoeducation.com and request that we delete such person’s Personal Information from our systems.
    
    
11. Complaints and Questions
    
    
    1. We regularly review our compliance with this Privacy Policy. When we receive formal written complaints, it is our policy to contact the complaining User regarding their concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between us and you.
       
       
    2. If you have any questions about this Privacy Policy, please feel free to contact us through the Services or write to us at: Passion Inc., Attention: Privacy Officer, 245 Eglinton Ave. East, Suite 430, Toronto, Ontario M4P 3B7; or at info@applytoeducation.com.
       
       

Last Revised: June 22, 2019