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.
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.
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 “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
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 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.
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
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
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.
How RWI Stores 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:
- Clicking “Edit Mode” in your digital room;
- E-mailing RWI at firstname.lastname@example.org OR email@example.com;
- Contact RWI using the Contact Page on the RWI website at www.SproutOwl.com; or
- Writing to RWI at 37 Armadale Ave., Toronto, Ontario, Canada, M6S 3W7.
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 firstname.lastname@example.org. 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
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.
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.
RelateWays, Inc and SproutOwl
37 Armadale Ave.,
Toronto, Ontario, Canada