個人情報保護方針 / Privacy Policy

Date of last modification: 2019-12-28

NIHONGO Montreal (“we”, “our”, “us”) recognizes the importance of your right to privacy and wants you to be familiar with how we collect, use and disclose any personal information that individually identifies you (e.g. name, phone number, email address).

This Privacy Policy explains how we collect, use, disclose and protect your personal information when you use our website (the “Site”) and our programs and services (the “Services”). This Privacy Policy outlines the terms and conditions you agree to when using our Site and Services. We will only collect, use and disclose your personal information in accordance with this Privacy Policy.

By using our Site and Services and supplying your personal information, you acknowledge that you have read and understood this Privacy Policy, and you agree and consent to the collection, use, disclosure and other processing of your personal information as outlined in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Site or Services or supply your personal information to us.

1. What Personal Information Do We Collect?

Personal information means any information about an identifiable individual. Anonymous Data means data that is not associated with or linked to any individual’s personal information or will not easily permit the identification of individuals. NIHONGO Montreal does not consider personal information to include Anonymous Data.

The types of personal information that we may collect include, but are not limited to:

• your name;
• your title;
• your address;
• your phone number;
• your email address;
• your IP address; and
• personal information you give us that we did not request (such as personal information you voluntarily put into an email to us).

2. Purposes for Collecting Your Personal Information

We collect, use and disclose your personal information in order to provide you with our Services. We also collect, use and disclose your personal information to comply with legal and regulatory requirements and as otherwise may be permitted or required by applicable laws. We will only use the personal information that we collect for the purposes for which it was collected. Specifically, we collect your personal information for the following purposes:

• to provide you with our Services as requested by you;
• to respond to your questions that you send by email or through our Site;
• to process and collect fees for service;
• to assess participant needs;
• to manage, develop and enhance NIHONGO Montreal operations, programs and services;
• to collect data for statistical purposes;
• to improve the Site and help us develop new services, apps, tools and Site features; and
• to meet any legal or regulatory requirements.

3. When Do We Collect Personal Information?

We may collect your personal information when you voluntarily provide it to us by using our Site or Services. For example, we may ask you to provide personal information if you:

• use our Site or our Services;
• register, update, create or sign in to an account on our Site and our Services;
• send us a question or comment by email, social media or phone;
• post comments or other content on our Site or Services;
• register to receive newsletters, articles and updates about our Services; and
• otherwise participate in features of our Site or our Services that ask for personal information.

Any personal information posted, used or disclosed on a Facebook page, Twitter page, LinkedIn page, Instagram page, YouTube page or other social networking page or site is subject to that website’s privacy policy, and is not subject to this Privacy Policy.

4. Limiting Collection of Personal Information

We limit the collection of personal information to that which is necessary to fulfill the purposes identified in this Privacy Policy and we collect, use and disclose your personal information in accordance with this Privacy Policy.

5. Use, Disclosure and Retention of Personal Information

Your personal information will not be used without your consent for purposes other than those for which it was collected or in accordance with applicable laws. From time to time, we may wish to use personal information for new or additional purposes, in which case we will amend the Privacy Policy to include these new or additional purposes and will obtain your consent through your continued use of our Site and Services.

To help safeguard your privacy, we will consider using non-identifiable information, such as coded or Anonymous Data that does not identify you whenever possible. We may generate Anonymous Data from personal information collected through the Site and Services by removing information that makes the data personally identifiable to an individual. We may use this Anonymous Data and aggregated data for any reasonable purpose and disclose such data to third parties in our sole discretion.

We may use and disclose your personal information to service providers, data processors and other third parties (“Third Parties”) under the following limited circumstances:

1. to service providers that help with our operations, Site and Services including, without limitation, for customer services, monitoring and analyzing Site activity, and operating and maintaining the Site. Such service providers and partner companies may only use your personal information for the purposes described in this Privacy Policy;
2. when necessary to protect our safety, property or other rights, our representatives, customers and users of the Site, including to detect and prevent fraud;
3. with your consent; or
4. when otherwise required or permitted by law.

In certain circumstances, personal information can be collected, used or disclosed without your consent. For instance, NIHONGO Montreal may disclose personal information without your prior knowledge or consent:

1. to a lawyer or other legal representative of NIHONGO Montreal;
2. to a government body or agency in certain circumstances;
3. to collect a debt, or comply with a subpoena, warrant or other court order; or
4. in circumstances otherwise required or permitted by law.

We retain your personal information only for as long as we need it to fulfill the purposes for which it was collected or as required by law.

NIHONGO Montreal will maintain schedules for records retention and destruction, which apply to personal information that is no longer necessary or relevant for the identified purposes for collection, or required to be retained by law or under contract. Such information shall be securely destroyed, erased or rendered anonymous.

6. Data Processors in Other Countries

As discussed in Article 5, we may engage Third Parties to perform certain services on our behalf and to otherwise provide the Services. These Third Parties may store, process and transfer personal information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada, such as the United States of America. As a result, personal information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to the laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Parties to maintain protections on personal information that are equivalent to those that apply in Canada.

7. Links to Other Sites

Our Site may contain links to other sites that are independently owned and operated by third parties. These other sites may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any sites owned and operated by any third parties. Other sites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy of each site you visit.

8. Cookies, Web Beacons and Other Similar Technology

As you interact with our Site, we may use automatic data collection technology and services that record and collect information that identifies your computer, tracks your use of our Site and collects certain other information about you and your surfing habits. This data collection technology may include cookies, web beacons and other similar devices on this Site to enhance functionality and navigation for our visitors. This technology does not personally identify you or extract any information from your computer. Data which would personally identify you is known only when voluntarily submitted.

A cookie is a small data file that is placed on the hard drive of your computer so that your computer will “remember” information when you visit a site. Web beacons and tags are small strings of code that are used in conjunction with a cookie and allow us to record activity on our Site. Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies. We may use web beacons on this Site to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize our Site and improve your experience at our Site. We may also include web beacons in HTML-formatted email messages that we send to determine which email messages were opened.

Information tracked through these mechanisms includes, but is not limited to:

1. your IP address;
2. the type of web browser and operating system being used;
3. the pages of the Site a user visits; and
4. other sites a user visited before visiting our Site.

We may also employ cookies and action tags (also known as single pixel gifs or web beacons) to collect information about your use of, and activities on, our Site for our use but also for use by third parties that serve advertisements about NIHONGO Montreal on other sites you may visit. For instance, we may use third party service providers, such as Google AdSense or AdWords, to serve advertisements on our behalf across the Internet. These advertising service providers may collect information about your visits to our Site, and your interactions with our services. In addition to the information about your visits to our Site, such advertising service providers may also use the information about your visits to other sites to target advertisements for services available from NIHONGO Montreal.

You can set your internet browser up so that you are notified when cookies are stored, you can decide in each individual case whether you want to accept cookies, or you can refuse to accept any cookies. However, if you do not accept cookies, you may be restricted in how you are able to use our Site. You can delete cookies which are already stored on your hard disk at any time. You will find more details on how to do this in the operating guide for your Internet browser program.

As described above, you may be able to set your browser to refuse cookies. If you refuse cookies you may still receive online advertising, but it may be less personalized.

9. Third Party Analytics

Our Site uses third party analytics services such as Google Analytics, a web analytics service of Google, Inc. ("Google").

Google Analytics uses "cookies" to analyze how you use our Site. The information generated by the cookie about your use of our Site (including your IP address) is sent to a Google server in the U.S. and stored there. Google will use this information to evaluate your use of our Site, compile reports on Site activity for our Site operators and to provide other site activity related internet services. Additionally, Google may transfer this information to a third party when required by law or in the case of a third-party processing information on Google's behalf. In no case will Google use your IP address in connection with any other information held by Google. You can set your internet browser to prohibit the installation of cookies, although we must point out that some features and functions of our Site will then be unusable. By using our Site, you consent to the processing of data about you collected by Google in the manner described and for the above-mentioned purpose. The consent for collection and storage of data can be withdrawn at any time in the future by clicking on the following link: https://tools.google.com/dlpage/gaoptout?hl=en. Given the debate concerning the use of analytical tools using full IP addresses, we wish to point out that our Site uses the "Anonymize IP" function of Google Analytics which works with a shortened form of IP addresses to avoid direct personal identification.

Furthermore, we use the cookies to carry out frequency assessments, page usage assessments and marketing assessments. For the aforementioned assessments, we utilize this cookie information without a link to your personal information, so it is completely anonymous.

10. Security

All staff with access to information are required, as a condition of employment, to respect the confidentiality of personal information and protect personal information in their control (regardless of format) against such risks as loss or theft, or unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security safeguards.

Safeguards may include physical measures (such as locked doors or locked file cabinets), organizational measures (such as staff training, limited access and security clearances) and technological measures (such as passwords and anti-virus software for computer systems).

Any personal information that you provide to us through our Site is exchanged on a secure server. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us.

Personal information shared with a third party for processing shall be protected through contractual agreements with requirements for confidentiality and appropriate safeguards.

11. Payment Information

We do not collect any payment information from you. We use commercially reasonable efforts to select an appropriate company to maintain the confidentiality and security of your payment information.

12. Individual Access and Accuracy of Personal Information

You may request access to your personal information which we may hold by contacting us at the contact information set forth below, and we will respond within the time periods provided for under applicable laws. We will need to verify your identity before providing you with the personal information we hold about you. There is no cost for such access request unless you require copies of records. We may not be able to provide you with access to your personal information if the information cannot be separated from the personal information of others, cannot be disclosed for reasons of security or commercial confidentiality, or is protected by legal privilege. If we cannot provide you with access to your personal information, we will advise you of the reasons access is being denied, unless we are prohibited by law from doing so.

You may request to update and change your personal information at the contact information set forth below. We shall endeavor to correct or complete any personal information which you advise us is inaccurate or incomplete. Where appropriate, the amended information shall be transmitted to third parties having access to such information. A statement of disagreement will be attached to records where a requested amendment cannot be made.

13. Children’s Privacy

We are committed to protecting the privacy of children and we do not knowingly solicit personal information from children under the age of 13. If a child has already provided us with personal information, his or her parent or guardian may contact us for the purpose of deleting this information.

14. Electronic Communications

We comply with Canada’s anti-spam legislation (CASL) and we will not send you electronic communications in contravention of this law. As part of signing up to receive our Services, you may have also opted in to receive email communications from us. If you opted-in to receive such communications, we may use the information to communicate with you regarding our Services, provide you with other information that you request, and/or improve our service offerings.

You will always have the opportunity to "unsubscribe" from receiving any of our email or other communications at any time and we will ensure that our emails include instructions on how to unsubscribe if you no longer wish to receive future emails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive Service-related messages.

15. User Content in Comments, Chat Rooms and Message Boards

If you post comments on the Site (such as commenting on a blog post) that may be available on our Site from time to time, you should know that when you voluntarily disclose your personal information on our comment boxes or other interactive areas where personal information can be posted, the information can be collected and used by other internet users. This may result in unsolicited messages from other posters or parties. We undertake no obligations as to the security of information you voluntarily post in comment sections of our Site or in other interactive features of our Site.

16. Terms and Conditions

Our Site is owned by NIHONGO Montreal. Any images, graphics, multimedia or content is copyrighted by NIHONGO Montreal and may only be used in the manner provided for in the terms and conditions outlined throughout this Privacy Policy. In addition, our Site contains names, logos, trademarks, service marks and other intellectual property which are the property of NIHONGO Montreal and may not be used for any purpose without the express written consent of NIHONGO Montreal. We will permit you to download or photocopy material displayed on our Site for your non-commercial personal use. However, any content or graphics extracted must prominently display copyright and other proprietary notices.

17. Changes to this Privacy Policy

We reserve the right to change or replace this Privacy Policy at our sole discretion at any time. Please check back from time to time to ensure that you are aware of any updates or changes to this Privacy Policy. We will post the most current version on our Site and we will indicate the date this Privacy Policy was last revised at the top of the page. Your continued access or use of this Site after any such changes constitutes your acceptance of the Privacy Policy as revised.

18. Your Consent to the Terms of this Privacy Policy

By using our Services and providing us with your personal information, you agree that we may collect your personal information and you voluntarily consent to the collection, use, disclosure and transfer of your personal information in accordance with this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Site or our Services or provide us with any personal information. If you do not understand the nature, purpose and consequences of us collecting, using and disclosing your personal information, please do not use our Site or our Services or provide us with any personal information, and contact us at the contact information set forth below so that we can address your questions or concerns.

Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified in this Privacy Policy at any time by contacting us at the contact information set forth below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

19. How to Contact Us

We welcome your feedback. If you have questions, comments or concerns about this Privacy Policy, or would like to do any of the following:

• see your personal information that you have already sent us so that you can correct, update or delete it from our files;
• if your child under 13 has used this Site and sent us personal information, delete that personal information from our files;
• ask that we not send you electronic communications or otherwise contact you; or
• report any violation of this Privacy Policy,

you may contact us through the contact form available on the website https://nihongomontreal.ca. We will endeavour to get back to you promptly.