Last modified: March 1, 2021
We are Elentra Corp. (“Company“, “we“, “us”, “our”), the company the provides the educational technology platform called Elentra (the “Platform”). Elentra is used by students, faculty, staff and administrative personnel at a variety of educational institutions including the one you are attending (or working at) and in connection with you have been granted access to the Platform (the “Institution”).
We respect your privacy and are committed to protecting it by complying with this policy.
This policy describes:
- How we collect, use, disclose, and protect the personal information of our customers and Platform users (“you“).
- Describes the types of information we may collect from you or that you may provide when you use the Platform.
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
Privacy laws generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
This policy applies to information we collect, use, or disclose about you:
- On the Platform or using its functionality.
- In messages between you and this Platform.
- In job applications.
- To the Institution
The Platform may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacypolicy of every website you visit.
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use the Platform (provided that such choice may also mean that you may not attend or work in your current role at the Institution). By accessing or using the Platform, you indicate that you understand, accept, and consent to the practices describedin this policy.
Information We Collect About You
We collect and use several types of information from and about you, including:
- Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, and any other identifier we may use to contact you (“personal information“).
- Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Platform feature.
- Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access the Platform, and usage details.
- Non-personal details about your Platform interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from the Platform (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain parts of the Platform, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
- Support: You may also provide us with information when you respond to surveys, communicate with our support centre about a support question or post a question in our public forums. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
- Job applicant information: If you apply for a job with us then you may provide us with information such as your name, contact information, resume or CV, and work authorization verification as part of the application process.
- Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use the Platform.
- Usage information: We collect information about your usage of the Platform. For example, we collect information about the actions that Platform administrators and users perform on the Platform, in other words, who did what and when. We also track information like your email address, Platform account settings and PHP settings. We also collect information about what happens when you use the Platform (e.g., page views, support document searches and interactions with us)along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide Platform services to you, get insights on how people use the Platform so we can make our Platform services better, and understand and make predictions about user needs.
- Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people use the Platform from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
- Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, the Platform may access the photos stored on your device when you upload a photograph to the Platform.
- Educational Information – We will get information about you arising from the functionality of the Platform. This includes information about the courses or other learning events you take/attend (or deliver), evaluations (including exam and proctoring schedules), marks, your professional accreditations, professor and instructor evaluations, residency or other job applications, grants applied for, research publications, information you post on discussion forums and the like.
- Institutional Information – We may also get information about you from the Institution. For example, we need certain information to authenticate you as a valid user of the Platform and to grant permission to you to use it. Also, professors and other instructions may upload information such as the results of various evaluations.
How We Collect Information About You
We use different methods to collect your information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
- User contributions. You may also provide information for us (a) to publish or display on discussion forums on the Platform; (b) in connection with course work and evaluations (and this may also be provided by the educational institution); or (c) in connection with other functionality of the Platform.
- Automated technologies or interactions, as you navigate through the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
Information You Provide to Us
The information we collect directly from you on or through the Platform may include:
- Information that you provide by filling in forms on the Platform. This includes information provided at the time of registering to use the Platform, posting or submitting material, and/or requesting further services. We may also ask you for information when you report a problem with the Platform.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Your search queries on the Platform.
- Residency or other job applications, course work and evaluations, research grants and applications and research publications
You may also provide information to be published or displayed (hereinafter, “posted“) on the forum areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to the Platform and you can make forums private, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
- Details of your visits to the Platform, including traffic data, location data, logs and other communication data and the resources that you access and use on the Platform.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical information and may include personal information and we may maintain it or associate it with personal information we collect in other ways. It helps us to improve the Platform and to deliver a better and more personalized service, including by enabling us to:
- Estimate usage patterns.
- Store information about your preferences, allowing us to customize the Platform according to your individual interests.
- Speed up the Platform.
- Recognize you when you return to Platform.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of the Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Platform. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see below under the heading Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of the Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Platform statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity).
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present the Platform and its contents to you.
- To provide you with information, products, content or services that you request from us.
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts with you.
- To notify you about changes to the Platform or any services we offer or provide though it.
- To improve the Platform, products or services, marketing, or customer relationships and experiences.
- To allow you to participate in interactive features, forums, or similar features on the Platform.
- To provide the functionality of the Platform to the Institution pursuant to our agreement with it;
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- the Institution;
- our subsidiaries, licensors and affiliates;
- in accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers and users is among the assets transferred; and
- to contractors, service providers, and other third parties we use to support the Platform and our business (such as analytics and search engine providers that assist us with Platform improvement and optimization);
in each case where they are each contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may share information that has been aggregated or de-identified, so thatit can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of the Platform.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
Information that you choose to make public on the Platform discussion formsis disclosed to those with access to such forums. Persons with such access may further disclose that information – so please bear that in mind when sharing such information. We will not be responsible for information you share with other users of the Platform.
We do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.
Transferring Your Personal Information
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support the Platform and our business (such as analytics and search engine providers that assist us with Platform improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacylegislation.
By submitting your personal information or engaging with the Platform, you consent to this transfer, storage, or processing.
The security of your personal information is very important to us. While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor the Platform for potential vulnerabilities and attacks.
We use physical, electronic, and administrative measures designed to secureyour personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Data is encrypted in transit and at rest. Currently we use Google Cloud as our hosting provider. Data is stored in a region agreed upon with the educational institution. For Canadian institutions this is currently Montreal and for US institutions a region close to them. Production data from other institutions is not stored on the same database as your Institution.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password or accreditation for access to the Platform, you are responsible for keeping this password and accreditation confidential. We ask you not to share your password / accreditation with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
To enhance the security of your account, we encourage you to enable advanced security settings, like Two Factor Authentication (if your institution supports that).
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfillthe purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or purposes contracted for the by the Institution. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Data will be deleted a reasonable period of time after our service contract terminates with the educational institution in respect of whom you are using the Platform.
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it.
The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In thelast 12 months, we collected the following categories of personal informationfrom California residents:
- Identifiers (like your name, contact information, and device and online identifiers);
- Characteristics protected by law (for example, you might provide your gender);
- Internet or other electronic network activity information (such as your usage of the Platform);
- Geolocation data (such as your location based on your IP address);
- Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
- Professional or employment-related information (for example, information you provide in a job application, research grant or residency application); and
- Inferences we make.
We collect personal information for the purposes described above and we share this information with the categories of third parties described above.
If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:
- Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
- Request deletion of personal information we collect or maintain;
- Opt out of any sale of personal information; and
- Not receive discriminatory treatment for exercising your rights under the CCPA.
Accessing and Correcting Your Personal Information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. Notwithstanding the foregoing, your personal information must accord with the Institution records and the Institution may control some aspects of changes to that information.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we mayhave destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Platform users.
Withdrawing Your Consent
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at firstname.lastname@example.org. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service and receiving this service may be a requirement of you attending or working at the Institution. We will explain the impact to you at the time to help you with your decision.
Contact Information and Challenging Compliance
171 Wellington Street, Suite 101, Kingston, ON, Canada, K7L 3E3
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.