Last modified: [APRIL 01, 2020]
COVENANT GROUP LTD.and our affiliates and subsidiaries ("Company"or "We") respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes how we collect, use, disclose, and protect the personal information of our customers and website users ("you"), describes the types of information we may collect from you or that you may provide when you visit and/or use our website (https://www.covenantgroupl.com),either mobile or desktop version called COVENANT GROUP WEB SITE(“Covenant Group”),which provide dedicated interaction between you andCovenant Group,and 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.
Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
This policy applies to information we collect, use, or disclose about our customers andCovenant Groupusers:
- OnCovenant Group.
- In email, text, and other electronic messages between you and us or Covenant Group.
- When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
- In person at our offices.
This policy does not apply to information collected by:
- Us offline or through any other means, including on any other software,web site or application operated by Company or any third party (including our affiliates and subsidiaries).
- Any third party (including our affiliates and subsidiaries),through any application or content (including advertising) that may link to or be accessible from or onCovenant Group.
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 useCovenant Group. By accessing or usingCovenant Group, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our PrivacyPolicy). Your continued use ofCovenant Groupafter 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,proof of identification (with or without picture),work experience,police check verification,social insurance number,emergency contact,spoken languages, allergies,Internet protocol (IP) address used to connect your computer or mobile to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you online or offline ("personal information").
- Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, 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 specificCovenant Groupfeature.
- Technical information, including your login information,browser type and version,time zone setting,connected plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to accessCovenant Group, and usage details.
- Non-personal details about yourCovenant Groupinteractions, including the full Uniform Resource Locators (URLs), clickstream to, through and fromCovenant Group(including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages,page or application interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page or application, or any phone number used to call our customer service number.
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 filling in forms or corresponding with us by phone, email, or otherwise.
- Automated technologies or interactions, as you navigate throughCovenant Group. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- Third parties or publicly available sources, for example, our business partners.
Information You Provide to Us
The information we collect directly from you on or throughCovenant Groupmay include:
- Information that you provide by filling in forms onCovenant Group. This includes information provided at the time of registering to use some features available on Covenant Group site for your benefit, like Applying for a Job,connectwith us, or Request Personnel, or any other similar where you will share information and requesting further services. We may also ask you for information when you report a problem withCovenant Group.
- Information that you provide in person at our offices.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Your search queries onCovenant Group.
You may also provide information to be published or displayed (hereinafter, "posted") on public areas ofCovenant Groupor transmitted to other users ofCovenant Groupor third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users ofCovenant Groupwith whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
- Details of your visits to and use ofCovenant Group, including traffic data, location data, logs, and other communication data and the resources that you access and use onCovenant Group.
- Information about your computer or mobile 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 Toolfor information on how you can opt out of behavioral tracking onCovenant Groupand 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 ways, that you provide to us, or receive from third parties. It helps us to improveCovenant Groupand 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 customizeCovenant Group according to your individual interests.
- Speed up your searches.
- Recognize you when you return toCovenant Group.
The technologies we use for this automatic data collection may include:
- Flash Cookies.Certain features ofCovenant Groupmay use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and onCovenant Group. Flash cookies are not managed by the same device or browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose YourInformation.
- Web Beacons.Covenant Groupand our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited the application or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by theDigital Advertising Alliance of Canadaoran opt-out tool created by theNetwork 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 Choices About How We Use and Disclose YourInformation.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
- To presentCovenant Group and its contents to you.
- To provide you with information, products, or services that you request from us.
- 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 match or connect you with job postings and/or advertisements that we deem relevant to you.
- To notify you about changes toCovenant Groupor any products or services we offer or provide though it.
- To improveCovenant Group, products or services, marketing, or customer relationships and experiences.
- To allow you to participate in interactive or similar features onCovenant Group.
- To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
- 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 follow the available and applicable opt out mechanism, which may include one or more of the following:checking the relevant box located on the form on which we collect your data,adjusting your user preferences in your account profile,or using the unsubscribe mechanism at the bottom of our e-mails. For more information, see Choices About How We Use and Disclose YourInformation.
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 may disclose aggregated information about our users without restriction.
- To our subsidiaries and affiliates.
- 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 ofCompany's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company 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. We may also use such aggregate information to help advertisers target a specific audience. 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 not opted out of these disclosures. For more information, see Choices About How We Use and Disclose YourInformation.
- To contractors, service providers, and other third parties we use to support our business (including but not limited to analytics and search engine providers that assist us withCovenant Group improvement and optimization or third party job search engines partnering withCovenant Group).
- To fulfill the purpose for which you provide it.
- 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 condition([www.covenantgroupl.com/information/TermsAndConditions])and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety ofCompany, 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 withCovenant Group improvement and optimization).
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.
By submitting your personal information or engaging withCovenant Group, you consent to this transfer, storage, or processing.
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:
- Third-Party Advertising.If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by using one or more of the following applicable opt out mechanisms:checking the relevant box located on the form where we collect your data on your user preferences or using the unsubscribe mechanism at the bottom of our e-mails.
- 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 using one or more of the following applicable opt out mechanisms:checking the relevant box located on the form on which we collect your data. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. Thisopt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.
- 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 using one or more of the following applicable opt out mechanisms:checking the relevant box located on the form on which we collect your data or logging into your account and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes.
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 theDigital Advertising Alliance of Canada or an opt-out tool created by theNetwork 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.
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.
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 toCovenant Group. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained onCovenant Group.
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. 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 13
Covenant Group is not intended for children under 13 years of age. No one under age 13 may provide any information to or onCovenant Group. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information onCovenant Groupor on or through any of its features/register onCovenant Group, make any purchases throughCovenant Group, use any of the interactive or public comment features ofCovenant Group, 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 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us firstname.lastname@example.org.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION WHEN APPLY FOR A JOB
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 after applied for a job you may send us an email email@example.com 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.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
- Information protected by solicitor-client privilege.
- Information that is part of a formal dispute resolution process.
- Information that is about another individual that would reveal their personal information or confidential commercial information.
- Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact our [Privacy Officer/[APP MANAGER]] at [firstname.lastname@example.org].
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 [email@example.com]. 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.
CONTACT INFORMATION AND CHALLENGING COMPLIANCE
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.