The Humphrey Group Privacy Policy
Introduction
This website (https://humphreygroup.com) is operated by The Humphrey Group Inc. (“The Humphrey Group”, “we”, or “us”). The Humphrey Group is committed to your privacy. This means we do not transfer, distribute, disclose, rent or sell any of your Personal Information (as defined below) to third parties except as provided for in this Privacy and Cookies Policy (the “Privacy Policy”).
Effective Date and Scope
This Privacy Policy is effective as of January 4, 2024.
The Humphrey Group has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), British Columbia’s Personal Information Protection Act (“PIPA”), the EU General Data Protection Regulation (“GDPR”), and other relevant privacy laws. This Privacy Policy governs our practices to the collection, use and disclosure of Personal Information that we collect through visitors and users of our website and individuals who otherwise provide us with Personal Information (collectively, “Users”). It also applies to The Humphrey Group's collection, use and disclosure of Personal Information of our employees, volunteers and contractors who work for or with us (“Employees”). By visiting and using our website and/or providing us with Personal Information (as defined below), you expressly consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.
We also process Personal Information as a data processor/service processor on behalf of our customers (please see “The Humphrey Group as a Service Processor” below).
Our website is not intended for or directed at children under the age of 16 years and we do not knowingly collect information relating to children under this age.
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Contacting Us If you have any questions about our Privacy Policy or your Personal Information, or to exercise any of your rights as described in this Privacy Policy or under privacy laws, you can contact us as follows:
By mail: By Phone (604) 568-7495
By email: contact@thehumphreygroup.com |
Definitions
To better understand this Privacy Policy, The Humphrey Group has set out some basic definitions to use when reading and interpreting it.
- Collection: the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
- Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes.
- Disclosure: making Personal Information available to a third party for that party’s own use.
- Employee Personal Information means personal information about an individual that is collected, used or disclosed solely for the purposes reasonably required to establish, manage or terminate an employment relationship or a volunteer work relationship between the organization and that individual.
- Personal Information: information about an identifiable individual that is recorded in any form, including Employee Personal Information, but does not include aggregated information or depersonalized that cannot be associated with a specific individual.
- Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of The Humphrey Group.
- Use: the treatment, handling and management of Personal Information by and within The Humphrey Group.
Accountability
The Humphrey Group is responsible for the Personal Information under our possession and control. We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.
Accountability for our compliance with the provisions of this Privacy Policy rests with the Privacy Office within The Humphrey Group, which has designated one or more persons to be accountable for compliance with this Privacy Policy. We may delegate to other individuals within the Humphrey Group to act on behalf of designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information. The Privacy Office has been created to ensure Users have a designated avenue to answer their privacy-related inquiries.
We will make known, upon request, the title of the person or persons designated to oversee our compliance with this Privacy Policy.
The Humphrey Group shall implement policies and practices to give effect to these principles, including:
- Implementing procedures to protect Personal Information;
- Establishing procedures to receive and respond to complaints and inquiries;
- Training staff and communicating to staff information about the organization’s policies and practices and their duties and obligations with respect to privacy; and
- Developing information to explain the organization’s policies and procedures.
What Personal Information Do We Collect?
Information That You Provide Us
You may provide us with information through our website, by email, over the phone or otherwise communicate or be in contact with us as a business customer or business contact, when you:
- request additional information about our services or company, or ask us to contact you;
- use our services as a client or customer;
- receive customer support;
- register with us to register for a training course that we offer; and
- make any comment or contribution on our website.
The categories of personal information you provide may include:
- first and last name;
- job title and company name;
- email address;
- phone number
- mailing address;
- password to register with us;
- your personal or professional interests;
- the category or type of organization you work for;
- information that you may submit to us while taking our courses, such as course assignments or discussion board comments; and
- any other identifier that permits The Humphrey Group to make contact with you.
Information That We Collect From You
When you participate in our coaching sessions, our coaches and instructors may take notes about items discussed during the session.
The Humphrey Group collects stores and uses information about your visits to our website and about your computer, tablet, mobile or other device through which you access our website. This includes the following information:
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technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location; and
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information about your visits and use of the website, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used.
How Do We Use Your Personal Information?
The Humphrey Group uses your Personal Information for the following purposes:
- to fulfill your requests for information about our company and our products and services;
- to enroll you in our leadership and training courses and provide you with Course Materials and other information and materials that you request from us;
- to communicate with you about your requests and inquiries;
- to recommend or to offer you other products and services based on your inferred interests;
- to communicate with you regarding customer service issues; and
- to protect the security or integrity of our website and our business.
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collected the information or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by The Humphrey Group.
Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to any individual. We may anonymize and aggregate the Personal Information we process in such a way as to ensure that individuals cannot be identified from it. We may use this anonymized and aggregated information for our own purposes including for testing our systems, research, data analysis, developing new products and services and improving our website and our products and services. We may share this anonymized and aggregated information with third parties.
Employee Personal Information
If you are an employee, volunteer or a prospective employee of The Humphrey Group, we will collect, use or disclose your Employee Personal Information, such as your name, contact information, resume, references, performance reviews, or salary information, only for the purposes reasonably required to establish, manage or terminate an employment relationship or a volunteer work relationship with you. We will provide you with written notice of the purposes for which we collect, use or disclose your Employee Personal Information before or at the time of collecting it, unless the purpose is obvious and you voluntarily provide the information. We will not require your consent for these purposes, as permitted by law.
We may also collect, use or disclose your Employee Personal Information with your express consent for other purposes related to your employment, such as training, performance evaluation, or recognition. You may withdraw your consent for these purposes at any time, subject to legal or contractual restrictions and reasonable notice. However, withdrawing your consent may affect your employment relationship with us. We will inform you of the implications of withdrawing your consent before you do so.
In some cases, after your employment or volunteer relationship with us ends, we may be contacted by other organizations and asked to provide a reference for you. Employee Personal Information that we will normally provide in a reference includes:
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Confirmation that an individual was an employee or volunteer, including the position, and date range of the employment or volunteering; and
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General information about an individual’s job duties and information about the employee or volunteer’s ability to perform job duties and success in the employment or volunteer relationship.
We will not disclose other Employee Personal Information about you without your consent.
Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except in certain circumstances as described below.
In certain circumstances, The Humphrey Group may collect, use or disclose Personal Information without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate where there is an emergency threatening the individual’s life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available.
Where appropriate, The Humphrey Group will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when The Humphrey Group wants to use information for a purpose other than those identified above).
In obtaining consent, The Humphrey Group will use reasonable efforts to ensure that a User is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by The Humphrey Group may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, we shall take into account the sensitivity of the Personal Information and the reasonable expectations of Users.
The Humphrey Group will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive. In certain circumstances, consent may be implied by a User’s actions. For example, providing us Personal Information to create an account is implied consent to use such information to provide the associated services.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, however, withdrawing consent may result in our inability to provide you with certain Services. In order to withdraw consent, you must provide notice to The Humphrey Group in writing.
Limiting Collection
The Humphrey Group collects only the Personal Information needed for the purposes identified in this Privacy Policy and will inform Users and Employees of these purposes.
The Humphrey Group as a Service Provider
We collect and process Personal Information on behalf of our clients in the provision of our service. In these circumstances The Humphrey Group is acting as a service provider and our clients remain the responsible organization in respect of Personal Information they provide to us or that we collect on their behalf. To the extent that we are acting as a service provider, we will process and use such personal information in accordance with our client’s instructions and any agreement in place with our customers. The Humphrey Group will only use such personal information for the purposes of providing the services for which our clients have engaged us.
Our clients are responsible for ensuring that these individuals’ privacy is respected, including communicating to the individuals in their own privacy policies to whom Personal Information is being transferred to and processed by.
As a service provider, The Humphrey Group may share Personal Information where instructed by our clients (the responsible organization). Where authorized by our client, we may also share Personal Information with third party service providers who work for The Humphrey Group and who are subject to security and confidentiality obligations. Moreover, The Humphrey Group may provide Personal Information to comply with a subpoena, warrant or other court order, government institution requesting the information upon lawful authority, or as may be otherwise required by law.
Where The Humphrey Group is acting as a service provider, we will refer any request from an individual for access to Personal Information which we hold about them to our clients. The Humphrey Group will not respond directly to the request.
The Humphrey Group will retain Personal Information which we process on behalf of our clients for as long as needed to provide services to our customers and in accordance with any agreement in place with our clients.
Personal information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to any individual. We may anonymize and aggregate the Personal Information we process in such a way as to ensure that individuals cannot be identified from it. We may use this anonymized and aggregated information for our own purposes including for testing our systems, research, data analysis, developing new products and services and improving our website and our products and services. We may share this anonymized and aggregated information with third parties.
Your Ad Choices: Interest-Based Advertising
Our website uses small pixel files (small images) and cookies (small text files) to keep track of your browser so that you will be recognized when you visit other websites where our third-party ad management providers may show you advertisements from us based on your visit to our website. Some of these advertisements may be customized to particular products and services that you viewed or they may be based on inferences about products and services that you might be interested in. This is called “interest-based advertising”.
These pixel files and cookies are generally valid for a limited number of days (usually no more than 90 days) and are provided by our ad management providers. We require our ad management providers to participate in the Digital Advertising Alliance of Canada’s Ad Choices Program. Visit the Digital Advertising Alliance of Canada: Your AdChoices website (http://www.youradchoices.ca) where you can find out more information about digital advertising and how you can opt-out of interest-based advertising. You can also opt-out of interest-based advertising using the link provided in any of our interest-based advertisements. Look for the Ad Choices icon or other link provided.
Please note that if you opt-out of interest-based advertising you may still see advertisements from us on other websites. However, they will not be customized based on your browsing history on our website. In addition, we will continue to customize our offers of products and services to you when you are on our website unless you block cookies from our website. If you block cookies on our website, certain functions, such as the “shopping cart” will not function properly because our website must recognize you as you move through the checkout process.
The Humphrey Group uses Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor use of the Services. The data is shared with other Google services. Google Analytics uses cookies to track information about traffic and visitors and sends such information: (i) to Google servers in the United States and (ii) to The Humphrey Group. Google Analytics does not identify any individual users or associate Your IP address with any other data held by Google. The Humphrey Group uses such information in the aggregate to compile statistical reports about the activity on our website as well as to benchmark the website to other third parties who also use Google Analytics. In addition, Google may use the collected data to contextualise and personalise the ads of its own advertising network. This information is used by The Humphrey Group to improve our services and their functionality. Google’s privacy policy can be found here: policies.google.com/privacy.
You may disable cookies using Your browser's settings. Please consult your browser's help function for information on how to disable cookies. Note that if you disable cookies, certain website features may not function to their fullest potential.
You may opt-out of Google Analytics by clicking here: tools.google.com/dlpage/gaoptout?hl=en
Do We Disclose your Personal Information to Others?
We may share your Personal Information with our service providers that help us with our business operations. For example, we may transfer information with service providers who provide us with marketing and promotional services. We require our service providers to keep your Personal Information secure. In addition, our service providers may not use or disclose Personal Information for any purpose other than providing the services on our behalf unless we or they have obtained your consent.
We may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our business or as part of a corporate reorganization or stock sale or other change in corporate control.
Subject to the foregoing, only The Humphrey Group’s and our service providers’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.
We may also disclose your Personal Information where we have reason to believe that it is relevant to the investigation or decision to investigate a breach of the laws of Canada, a province or territory of Canada, or a foreign jurisdiction, and we are legally permitted to do so.
Law Enforcement Requests
We will disclose Personal Information without your knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your personal information.
Storage Outside of Canada
We will generally only store Personal Information in the jurisdiction it was collected from or generated at. However, we may transfer Personal Information to our service providers outside of Canada. We require that our service providers safeguard your Personal Information. However, if your Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require such service providers to maintain protections on Personal Information that are equivalent to those that apply in Canada.
How Do you Access and Modify your Personal Information or Make a Complaint?
You have the right to request access to or correction of your Personal Information that we hold, subject to certain exceptions under the law. To make such a request, or if you have any questions or concerns about how we collect, use, or disclose your Personal Information, please contact our Privacy Office. We will respond to your request within a reasonable time and provide you with the reasons for any refusal or correction. As noted above, when we act as a service provider on behalf of clients, we will direct such requests to our applicable client.
If you are not satisfied with our response, you may make a complaint to our Privacy Officer, who will investigate and attempt to resolve the matter. If you are still not satisfied, you may file a complaint with the Office of the Information and Privacy Commissioner of British Columbia (OIPC), which oversees our compliance with the Personal Information Protection Act (PIPA). The OIPC's contact information is available on its website: https://www.oipc.bc.ca/. Alternatively, if you are located outside of British Columbia, you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC), which oversees our compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA). The OPC's contact information is available on its website: https://www.priv.gc.ca/en/.
How Do We Protect Your Personal Information?
We have implemented administrative, technical and physical measures to safeguard your Personal Information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access of Personal Information. This includes:
- utilizing access controls and firewall controls of computer servers;
- limiting access of employees to, and the use of, Personal Information through the use of passwords and graduated levels of clearance.
- the use of pseudonymization and encryption of Personal Information, where appropriate;
- measures to ensure the ongoing confidentiality, integrity, availability and resilience of its systems and services; and
- a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of Personal Information.
Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit Personal Information to us using our website if you consider that information to be sensitive.
Links to Third-Party Websites
You may be able to access third-party websites through links available on our websites. These links are provided for your convenience. We do not have any control over those third-party websites and we do not provide any guarantee that the privacy practices of the hosts of those websites meet our standards. Your use of such third-party websites is at your own risk and will be governed by the privacy policies of those websites and not by this Privacy Policy. Do not transmit Personal Information using those websites without reading the privacy policies governing those websites.
Notice to Persons Outside of Canada
This Privacy Policy is governed by the laws of Canada and applicable provincial laws. By submitting Personal Information to us, you understand that your Personal Information will be subject to the laws of Canada and applicable provincial laws.
Privacy Policy Changes
The Humphrey Group may update this Privacy Policy from time to time to reflect any changes in regarding how we collect, use, or disclose your Personal Information. 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 in this Privacy Policy. We will indicate at the top of this page the date this Privacy Policy was last revised. Your continued access or use of this Site after any such changes constitutes your acceptance of the Privacy Policy as revised and will be binding on you.