Privacy Policy

WEBSITE PRIVACY POLICY OF OCCUPATIONAL SAFETY GROUP INC.

Draft last modified: 9 March 2023

INTRODUCTION

Occupational Safety Group Inc. is a Canadian Company focused on helping businesses train their employees and independent contractors by ensuring up-to-date and class leading health and safety training. Read more below to find out how exactly we do this.

Occupational Safety Group Inc. and our affiliates and subsidiaries (“Company”, “OSG” or “We”) respect your privacy and are committed to protecting it by complying with this policy. We understand that as a data subject, your information is important to you.

This policy describes:

• How we collect, use, disclose, and protect the personal information of our customers and website users (“you”).
• The types of information we may collect from you or that you may provide when you visit this website (our “Website”), or affiliate websites. This may include, but is not limited to: https://osg.ca/, https://greenbook.ca/, and https://learninglogin.com/.
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes as set out in this policy.

Privacy laws in Canada, and the European Union may generally define “personal information” as any information about an identifiable individual, consumer, or household, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Note, data protection laws in several jurisdictions draw comparison between the “controllers” and “processors” of personal information. In general, OSG performs the role of a processor on behalf of our clients who are the controllers.

This policy applies to information we collect, use, or disclose about you:

• On this Website.
• In email, phone and other electronic messages between you and this Website.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
• Through any of our affiliate companies.
• including on any other Company or third-party website (including our affiliates and subsidiaries).

The Website 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 privacy policy of every website you visit.

This policy DOES NOT apply to information that:

• You provide to or is collected by any third party including our affiliates and subsidiaries, through any application or content (including advertising) that may link to or be accessible from or on the Website. To be clear, OSG does not collect the same information as our clients. For information on our client’s privacy policies, please review their privacy policy, and contact their Privacy Officer.
• Information we collect offline, including phone calls, letters, and work applications. For work applications, we work with JazzHR. Please consult their privacy policy for any further information on their policies.

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 our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

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, and any other identifier we may use to contact you (“personal information”). We also collect any other information you choose to send us. Please do not provide us with your billing and account information, social insurance number, or health card number. Furthermore, do not provide us with any criminal, or offence history.
• We provide an opportunity for any user to unsubscribe from our emails or opt-out of contact for marketing or data purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or by e-mailing to privacy@osg.ca.
• 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 Website 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 our Website, and usage details.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, search terms and search engines, page response times, download errors, length of visits to certain pages, 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.
• Analytics, such as Google Analytics
• When you visit our websites, we may automatically collect certain information, such as:
  • Ad group, keyword, and other data about the ad you clicked on to navigate to our website
  • This is standard practice for websites, and is not used for any purpose other than to evaluate how we can design the site to best serve your needs.

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 registering online, or use of any of our products or services.
• User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties.
• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, domain, country and information collected through cookies, web beacons, and other tracking technologies.
• Third parties or publicly available sources, for example, our business partners.
• The use of unique phone numbers to record calls.

INFORMATION YOU PROVIDE US

The information we collect directly from you on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Details of transactions you carry out through our Website and of the fulfillment of your orders.
• Your search queries on the Website.
• Information you post to any “third party affiliates”

INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

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 way or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

THIRD PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see below for “Choices About How We Use and Disclose Your Information”.

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 our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To provide you, or your employer the status of your course module.
• To email you regarding your progress on our website.
• 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 carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To improve our Website, products or services, marketing, or customer relationships and experiences.
• To allow you to participate in interactive features, social media, or similar features on our Website.
• To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• To confirm up-to-date billing information, or subscription status.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at privacy@osg.ca. For more information, see below for “Choices About How We Use and Disclose Your Information”.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We do not sell any of your information to third parties. However, we may disclose aggregated information about our users, and information that does not identify any individual.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To the controller of the website in which you input data.
• 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 Occupational Safety Group Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by OSG about our customers and users is among the assets transferred.
• To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers’ advertisement to that target audience.
• To third parties to market their products or services to you if you have consented to these disclosures. We may contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see below for “Choices About How We Use and Disclose Your Information”.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

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.
• To enforce or apply our terms and conditions of use https://learninglogin.com/help/disclaimer, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Occupational Safety Group Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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 our business (such as analytics and search engine providers that assist us with Website 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 privacy legislation.

You are welcome to contact us at privacy@osg.ca to obtain further information about Company policies regarding service providers outside of Canada.

• By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
• The information supplied to us may be collected, used, disclosed, stored, or processed in Canada, the United Kingdom, or the European Union.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy@osg.ca. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request to privacy@osg.ca.
• We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted using SSL technology. Our data is stored in Canadian.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password 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 our Website. 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 Website.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Generally, we retain your data for 5 years. 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.

CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@osg.ca.

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.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at privacy@osg.ca to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

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 may have 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 are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at privacy@osg.ca.

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 privacy@osg.ca. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. It may take up to 3 business days to fulfill your request.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify through a notice on the Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Privacy Officer
3330 Dingman Drive
London, ON N6E 3W8
or our number 1-800-815-9980

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.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA

In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European consumers and users, this Privacy Policy outlines the legal basis on which we process your Personal Information and provides other information required by the GDPR.

In addition to the common rights granted to all users of the Site who provide us with Personal Information, the GDPR provides the following additional rights to residents of the European Economic Area:

• Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Information, as permitted by law.
• Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances.
• Right to data portability (Art. 20 GDPR): You have the right to receive the Personal Information that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
• Right to object (Art. 21 GDPR): You have the right to object to our processing of your Personal Information, as permitted by law.
• Right to lodge a complaint before the Data Protection Authority (Art.77 GDPR): We encourage you to contact us directly and allow us to work with you to address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Information relating to you infringes applicable data protection laws.
• Right not to be subject to a decision based solely on automated processing (Art. 22 GDPR): You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning or significantly affecting you, as permitted by law.
• Collection of Cookies: If you are a European resident, cookies are only collected once you have logged into the learninglogin.com training portal. We collect only the necessary cookies for the purpose of this website.

GOVERNING LAW

Occupational Safety Group Inc. controls and operates this Site in Canada. Our online privacy practices are governed by the laws of Canada and Ontario, which may differ from privacy laws in your province, state or home country. By submitting your Personal Information to this Site or to an affiliate, you consent to the transfer of your Personal Information to any country and its use and disclosure in accordance with Canadian federal and Ontario provincial law and with this Privacy Policy.

FOR MORE INFORMATION OR ASSISTANCE

If you have any questions regarding this Privacy Policy or the privacy practices of OSG or its affiliates, or if you require assistance to withdraw your consent to our processing of your Personal Information or wish to request that your Personal Information be deleted, please contact us by sending an email to privacy@osg.ca or writing to us at:

Occupational Safety Group Inc.
3330 Dingman Drive
London, ON N6E 3W8
Attention: Chief Privacy Officer.