Privacy

Privacy Policy

RelateWays Inc. (“RWI”) and SproutOwl is committed to maintaining the integrity and privacy of the customers, practitioners and end users who access and use the RWI proprietary platform and related RWI platform and programs (the “RWI Platform”), including you (“you”). This privacy policy (“Privacy Policy”) explains how RWI, directly and indirectly through the RWI Platform and users of the RWI Platform, collects, uses, shares, retains and protects personal information that may identify you or other individuals.

If you are under 18 years old you must to go through this Privacy Policy with your parents. If you don’t understand anything in this Privacy Policy, you should talk about it with your parents. Please, don’t use the RWI Platform until you have talked about this Privacy Policy with your parents.

RWI only collects, uses and discloses personal information in order to develop and provide you and other RWI customers, practitioners and end users with the services requested, to deliver the services provided by the RWI Platform, and to improve the experience of customers, practitioners and end users using the RWI Platform. RWI only collects, uses, discloses and stores end user personal information as described in this Privacy Policy.

Your Acceptance of Privacy Policy

By using the RWI Platform, you signify your acceptance of this Privacy Policy.  If you do not agree with this Privacy Policy, please do not use the RWI Platform or open an account with RWI.

If you are under 13 years old you cannot open an account with RWI. If you are under 13 years old, please do not register with RWI or send any information to RWI. If RWI learns that information from a person under the age of 13 has been submitted, directly or indirectly, to RWI for or through the RWI Platform, RWI will use reasonable efforts to delete the information as soon as possible.

If you are under 18 years old you must to go through this Privacy Policy with your parents.

How RWI Collects Personal Information

RWI collects personal information from practitioners on a voluntary basis, from RWI customers, and through a practitioner’s use of the RWI Platform as described below.

RWI collects personal information from each end user on a voluntary basis, from RWI customers and the practitioners retained by those customers, and through an end user’s use of the RWI Platform as described below. RWI customers and the practitioners retained by those customers are called “Hosts”.  In some cases, RWI Platform practitioners may also be customers of RWI

Personal information voluntarily provided

When a practitioner chooses to register to use the RWI Platform, that practitioner voluntarily provides to RWI, and RWI directly collects, through the RWI Platform, personal information including the practitioner’s: full name, business name or practice name, telephone number, e-mail address, gender, primary practice type and area of focus, practice speciality, education, years of practice experience, country of residence and city of residence.

When an end user chooses to register to use the RWI Platform, that end user voluntarily provides to RWI, and RWI directly collects, through the RWI Platform, personal information including the end user’s: full name, e-mail address, gender, age range, occupation, occupation role, country of residence, city of residence, personal strengths (selected from a list), and areas to focus on for personal development (selected from a list).

As well, when an end user uses the RWI Platform, RWI, directly or indirectly through Hosts, may collect information about that end user’s specific personal goals, steps that end user is taking toward achieving those goals, and notes and additional information in connection with those goals. As well, RWI, directly or indirectly through Hosts, may collect voice recordings or videos of end users and practitioners for which it or the applicable Host will obtain a separate, express prior written consent from each such end user or practitioner. The personal information described in this paragraph may be collected when an end user has a conversation with a practitioner in one of the RWI Platform’s private rooms, or when an end user adds notes to his/her journal section of the RWI Platform

When a person contacts RWI with any questions, comments, requests or feedback related to RWI or the RWI Platform directly or through any RWI website, RWI usually collects the full name and e-mail address of that person as well as any other information that person voluntary provides.

Personal information collected from Hosts

In order to use the RWI Platform, a practitioner may be invited to use the RWI Platform by RWI and/or an RWI customer. In order to use the RWI Platform, an end user may be invited to use the RWI Platform a Host.  If an end user or a practitioner is invited to use the RWI Platform by a Host, the Host may provide to RWI personal information about such end users and practitioners, including their name and e-mail address, a unique identifier and other information that connects an end user or practitioner to the applicable RWI customer related to the purpose of the agreement between RWI and the applicable RWI customer.

If RWI collects any personal information from a Host, it will have entered into a contract with that Host which requires the Host to ensure, and provide assurances to RWI, that it has each end user’s or practitioner’s informed and meaningful consent to collect and use their personal information and to disclose that personal information to RWI to be used and disclosed in accordance with this Privacy Policy. The applicable Host is entirely responsible for the collection, use and disclosure of information it provides to RWI. Any collection, use or disclosure by a Host (and not RWI) is not the responsibility of RWI and is not covered by this Privacy Policy.  If personal information has been provided to RWI by a Host, it will be used, disclosed and stored by RWI in accordance with this Privacy Policy, and it will be connected and linked with all of the personal information collected by RWI in accordance with this Privacy Policy.

If you want to know if RWI has obtained any of your personal information from a Host, or if you want RWI to stop using personal information collected from a Host, or if you want RWI to delete this personal information, you can contact RWI anytime as described in this Privacy Policy.

Personal information collected through use of the RWI Platform

Each time you use the RWI Platform, RWI may collect information, including some of your personal information, through your IP address and by using cookies and web beacons as described below.

  • An Internet Protocol (“IP”) address is a number that automatically identifies the computer/machine you have used to access the Internet. RWI uses your IP address to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider. RWI may use IP addresses to conduct analyses and performance reviews of, and to administer, the RWI Platform and RWI’s websites.
  • A “cookie” is a piece of information that a website transfers to a user’s computer for purposes of storing information about a user’s preferences. Cookies identify a user’s computer and can be considered personal information. RWI uses cookies to provide useful features when you visit the RWI Platform or any RWI website. You can set your Internet browser to refuse cookies, but some portions of the RWI Platform may not work properly if you refuse cookies.
  • A “web beacon” is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of websites. Some web beacons may be unusable if you elect to reject their associated cookies. RWI may use web beacons in conjunction with cookies to compile statistics about your use of the RWI Platform and RWI websites.

How RWI Uses Personal Information

RWI will only use personal information as specified in this Privacy Policy.

As described below, RWI uses personal information voluntarily provided in order: (a) to address specific requests for information about RWI’s products or services (including the RWI Platform); (b) to maintain end user and practitioner accounts and profiles; and (c) to provide you with notices under any agreement between you and RWI; and (d) to deliver the services provided by the RWI Platform, including: maintaining continuity and focus of end user conversations that support the progress of each end user using the RWI Platform; and allowing each end user to self-assess, enhance engagement with a Host and learn in dialogue with a Host.

  • If you contact RWI, including through e-mail or through the “contact us” function of the RWI Platform or one of RWI’s websites with questions, comments, requests or feedback, RWI will use your name and e-mail address and other information that you voluntary provided to RWI to communicate with you and respond to you.
  • If you have an account to use the RWI Platform, RWI will use your name and e-mail address to identify you and maintain your account, and will link to your account all of the personal information collected by RWI about you in accordance with this Privacy Policy, in order to deliver to you the services provided by the RWI Platform. RWI retains all of this information (including your personal information) for as long as you have a RWI account.
  • If you have an account to use the RWI Platform, RWI may also use your e-mail address to communicate with you by e-mail about RWI, the RWI Platform, scheduled appointments, certain changes to RWI Platform, certain changes to the RWI Platform end user agreement, your use of the RWI Platform, or RWI’s promotional or marketing efforts.
  • If RWI collects any personal information from a Host, RWI will use that information to identify end users and practitioners and maintain end user and practitioner accounts in order to deliver the services provided by the RWI Platform. RWI will also link all of information about a particular end user or practitioner provided to RWI by a Host with all information collected by RWI about that end user or practitioner in accordance with this Privacy Policy in order to deliver the RWI Platform services.

If RWI collects any personal information through its use of cookies and web beacons, it will only use that information to improve user experiences with the RWI Platform or any RWI website by recognizing an end user or practitioner when they use the RWI Platform or any RWI website and studying how each end user and practitioner uses and navigates through the RWI Platform or any RWI website so that RWI can improve the design, content and function of the RWI Platform and it’s websites. RWI may hire third-party service providers to assist in the collection and analysis of cookies and web beacons, but no personal information is disclosed to these third party service providers.

RWI may remove personal identifiers, such as names, from personal information and use and maintain the non-personalized information in non-personalized, aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information.

How RWI Shares Personal Information

Unless it has consent to do so, RWI will not share or disclose personal information other than as described in this Privacy Policy.  RWI will not sell, rent, license, or trade personal information to third parties for their own direct promotional or marketing use without express consent to do so.

Disclosing personal information to Hosts

RWI will not disclose practitioner personal information to any third party other than to the applicable RWI customer. RWI will not disclose end user personal information to any third party other than to the applicable Host(s).

RWI will disclose end user personal information to the applicable Host(s) in order to allow such Host(s) to: identify what users have registered for the RWI Platform through its account; learn how such end users are using the RWI Platform; and deliver the services provided by the RWI Platform, including by maintaining continuity and focus of end user conversations that support the progress of each end user using the RWI Platform, and allowing each end user to self-assess, enhance engagement with a Host and learn in dialogue with a Host. RWI is not responsible for any Host’s disclosure of personal information to any third party. For more information about the use of personal information by any particular Host, you should contact that Host directly.

Sharing personal information with third parties assisting RWI

RWI may share personal information with trusted third parties that work with, or on behalf of, RWI to process information, including information processing companies. These companies do not have any independent right to use, share, disclose or retain the personal information of any end user or practitioner.

Sharing anonymous information with third parties

RWI may remove personal identifiers, such names, screen names and e-mail address from personal information and maintain the information in non-personalized, aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information. RWI may give or sell such anonymous, aggregated statistical information to RWI’s affiliates, business partners, service providers and vendors. If it does so, RWI will not disclose any personal information.  Except as described in this Privacy Policy, unless RWI seeks and receives express approval, RWI will not share any personalized, un-annonymized personal information with third parties.

Disclosing personal information under special circumstances

RWI may disclose personal information, including about end users and practitioners, to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise RWI’s legal rights or to defend against legal claims, or if RWI believes it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

If RWI is to be sold, merged or amalgamated or is to sell or dispose of substantially all of its assets, personal information may be transferred to a potential purchaser if, and to the extent, necessary for the purposes of helping the potential purchaser to decide whether to proceed with the sale and completing the sale. If such a sale, merger, acquisition or disposal is completed, the successful purchaser may use and disclose personal information only to the extent described in this Privacy Policy if the information relates solely to the carrying on of the business or activity or the carrying out of the objects for which the sale, merger or acquisition took place.

How RWI Stores Personal Information

RWI will store and retain all of an end user’s or a practitioner’s personal information for as a long as that person maintains an account with RWI to use the RWI Platform so that RWI can deliver to end users and Hosts the services provided by the RWI Platform that end users and Hosts want and expect to receive from RWI. If an end user or practitioner cancels his/her RWI account in accordance with this Privacy Policy, that person’s de-identified personal information may remain in RWI’s databases in annonymized form, and may be used and disclosed by RWI in annonymized, aggregate form only in accordance with this Privacy Policy for as long as the applicable RWI customer of the RWI Platform remains contractually engaged with RWI.

If RWI has disclosed your personal information to a third party (including a Host) in accordance with this Privacy Policy, RWI has no control over, and is not responsible for, how long and how such third party stores that personal information.

Decisions about Personal Information

Amending and updating personal information and consents

An end user or practitioner can, within 30 days, at no cost, and at any time: review his/her the personal information provided to RWI; withdraw his/her consent for RWI’s use and disclosure of personal information; update or amend current account information, including current personal information; or cancel his/her RWI account by:

Even after you have updated or amended you current personal information, some of your historical personal information will be stored and retained by RWI in accordance with this Privacy Policy.

When inquiring about or updating your personal information, RWI may ask you to verify your identity before it can act on your request.

Cancelling an account

An end user or a practitioner can cancel his/her account by clicking the related button on the platform and following the directions and you may confirm by contacting us through www.SproutOwl.com/contact-us/ or at support@relateways.com.  If an end user or practitioner cancels his/her RWI account he/she will not be able to use any part of the RWI Platform.

As described above, if you cancel your RWI account, your personal information may remain in RWI’s databases and may be used and disclosed by RWI for as long as the applicable RWI customer of the RWI Platform remains contractually engaged with RWI. Despite this, if you cancel your RWI account, RWI will use commercially reasonable efforts to promptly remove your personal identifiers from its databases and restrict the use and disclosure of your personal information when it is no longer required to deliver the RWI Platform services to the applicable Host.

Referrals and Links

The RWI Platform and RWI’s websites may contain links to third party websites that may offer information of interest. This Privacy Policy does not apply to those third party websites or those third parties. RWI strongly recommends that you review those third party privacy policies individually.

Security

RWI understands that it is important to store all personal information in a secure manner. Personal information is stored using industry standard physical, technical, organization and administrative safeguards to secure data against foreseeable risks, such as theft, unauthorized use, access, disclosure, copying, destruction or modification. While RWI attempts to ensure that the RWI Platform is secure and reliable, the confidentiality of any communication or material transmitted to or from the RWI Platform, through e-mail, or through any RWI website cannot be guaranteed. The Internet is not a secure medium.

RWI limits access to end user and practitioner personal information within RWI to individuals on a need-to-know basis.  RWI makes its employees, agents and contractors aware of the importance of protecting personal information.

End user and practitioner personal information may be transferred, processed and stored on servers in countries outside of Canada, including the United States, and therefore may be subject to different laws than those applicable in Canada. While RWI undertakes to protect personal information when it is transferred outside of Canada, the laws of other jurisdictions may require the disclosure of any personal information to governmental authorities under circumstances that are different than those that apply in Canada and are contemplated under this Privacy Policy.

Children’s Privacy Protection

RWI understands the importance of protecting the privacy of children in the interactive online world.

The RWI Platform may be used by individuals between the ages of 13 and 18. No one under the age of 13 should use, or be invited or encouraged to use, the RWI Platform and RWI will not knowingly collect personal information from or about any person under the age of 13.  RWI obtains meaningful consent from individuals between the ages of 13 and 18 who use the RWI Platform by using tools and processes that are designed and appropriate for those individuals to ensure that those individuals understand how their personal information will be used and disclosed.

A Host may provide to RWI personal information about individuals between the ages of 13 and 18 only in compliance with all applicable privacy laws and other applicable laws, regulations and guidelines regarding the protection of personal information, and only if that Host it has entered into a contract with RWI which requires the Host to ensure, and provide assurances to RWI, that it has complied with all such laws in the collection, use and disclose of such personal information.

RWI encourages parents and guardians of individuals between the ages of 13 and 18 who use the RWI Platform to spend time with their children to discuss this Privacy Policy and their use of the RWI Platform. Parents and Guardians should be actively involved in their child’s use of the RWI Platform.

Policy Updates

This Privacy Policy may be revised from time to time as RWI adds new features and services to the RWI Platform, as RWI’s business evolves, as laws change, and as industry privacy and security best practices evolve. If RWI makes any change to this Privacy Policy regarding collection, use, disclosure or storage of personal information, RWI will provide notice on the its website at www.SproutOwl.com. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your continued use of the RWI Platform or any RWI website following the posting of changes to this Privacy Policy will mean that you accept those changes. RWI recommends that you check its website at www.SproutOwl.com periodically in order to review the current Privacy Policy. You can tell if this Privacy Policy has changed by checking the effective date that appears at the bottom of this Privacy Policy.

Questions?

If you have any questions, inquiries or complaints about this Privacy Policy or about RWI’s handling of your personal information, please contact RWI as follows.

RelateWays, Inc and SproutOwl
37 Armadale Ave.,
Toronto, Ontario, Canada
M6S 3W7

Attention: Privacy Officer
Telephone: 647-998-9250
E-mail: support@relateways.com OR  info@relateways.com

Update

Privacy Policy last updated: [November 9, 2013]

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