PRIVACY POLICY

We at Enabling Adaptations Inc. (“Company”, “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you, our visitors, users and customers. This Privacy Policy (“Policy”) addresses our data collection practices and describes your rights to access, correct, or restrict our use of your personal information.

 

Unless we state otherwise, this Policy applies when you visit or use the Company website (enablingadaptations.com, skootlebox.com, social media channels) and related platforms (“Sites”).

 

By using the Sites, you agree to the terms of this Policy, our Terms of Service, incorporated herein, our and any other written agreement that governs your use of our Sites. You should not use our Sites if you do not agree with the terms and conditions contained in such agreements.

WHAT IS CONSIDERED PERSONAL INFORMATION?

WHAT INFORMATION DO WE COLLECT?

We collect information from you when you register on the site, place an order, enter a contest or sweepstakes, respond to a survey or communication such as e-mail, or participate in another Site feature.

 

When ordering or registering, we may ask you for your name, e-mail address, mailing address, phone number, credit card information or other information. You may, however, visit our site anonymously.

 

We also collect information about gift recipients so that we can fulfil the gift purchase. Like many websites, we use cookies to enhance your experience and gather information about visitors and visits to our websites. Please refer to the Do We Use Cookies section below for information about cookies and how we use them.

 

Here are some examples of data we collect from information you provide us:

 

User Account Data: When you purchase or are granted access to one of our products (such as a program, an online course, a membership site, etc.), you need to create a User Account. When you create your User Account, you must provide certain information like your email address, and password. We collect data regarding which products you have access to, how much you paid for those products or services, the first date you signed into your User Account, the number of times you’ve signed into your User Account, the date of your last activity in your User Account and which lessons you’ve completed. For your security, the Company is unable to view your User Account password.

 

Payment Data: If you purchase a Company product or service, we collect certain data about your purchase as necessary to process your request. You must provide certain payment and billing data directly to our third-party payment processing partners, including your name, credit card number, security code, expiration date, billing address, and postal/zip code. For your security, the Company does not have access to or store sensitive cardholder data, such as full credit card numbers or card authentication data.

 

Online Webinars: In order to enroll in one of our online webinars, you must provide certain information like your name and email address so that we can communicate information about attending the online webinar. We collect data regarding which online webinar(s) you enrol in, whether you attend the webinar and if so, for how long, whether you purchased a product during an online webinar, as well as any feedback in the form of responses to surveys and/or chat features that may be enabled for an online webinar. Such online webinars are hosted via third-party platforms, therefore, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of those third parties.

 

Shared Public Content: Our Sites may permit you to publicly interact with us and other users, share content, post comments, and ask or answer questions. Such shared content may be publicly viewable by others depending on where it is posted. If such information is shared on a third-party platform, such as a social media site, the collection, use, and sharing of your data will also be subject to the privacy policies and related agreements of that third party.

 

Quizzes, Forms, Giveaways, Promotions, and Surveys: We may invite you to complete a quiz, form, survey, provide feedback, or participate in a promotion (like a giveaway), either through our Sites or a third-party platform. If you participate, we will collect and store the data you provide us as part of your participation, such as your name and email address and any other requested feedback. If you submit this information via a third-party platform, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.

 

Electronic Communications from Company: If you elect to receive email notifications from us, we collect your name and email address so that we can send you email communications about the requested information, products, and services.

 

Customer Support: If you contact us (via email, phone, text, messaging platform, or through our social media channels), we may collect and store your name, email address, telephone number, the content of your message, information about your business and any other data you provide. Some Site transactions may require us to telephone or text the customer.

 

WE MAY PROCESS THE FOLLOWING CATEGORIES OF PERSONAL DATA ABOUT YOU:

Communication Data includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

 

Customer Data includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

 

User Data includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

 

Technical Data includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

 

Marketing Data includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as sales offers, affiliate offers, free contests with give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

 

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests, namely to grow our business.

Automatically Collected Information through Tracking Technologies

When you visit or access the Sites, including our email communications, we use tracking technologies like cookies, pixels, web beacons, tags, and other tracking technologies to collect information about your engagement, as well as your browsing and purchasing behaviour.

 

These tracking technologies include:

 

Clickstream Data: Through web site access logs, we collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our Sites. This information is used for internal purposes for research and development, user analysis and business decision making, all of which provides better services to our users. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties for data processing.

 

Cookies: A cookie is a small amount of data that is sent to a website user’s browser from a Web server and is stored on the computer’s hard drive. We use non-identifying cookies to provide easier site navigation. Our Sites can still be used if your browser is set to reject cookies. Our cookies do not generate personal data, do not read personal data from your machine and are never tied to anything that could be used to identify you. Information gathered through cookies may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.

 

Web Beacon Technologies. We may also use Web beacon or other technologies to better tailor our Sites to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Sites, a non-identifiable notice of that visit is generated which may be processed by Company or its data processors. Web beacons usually work in conjunction with cookies. If you do not want cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

 

We use these tracking technologies to deliver, measure, and improve our Sites – whether accessed through a browser or a mobile device – in various ways. In particular, these technologies help: make our Sites easier to use; better tailor our Sites to your interests and needs; carry out profiling activities in order to learn more about you; offer you tailored advertising based on your behaviour on our Sites; provide better customer service, and compile anonymous, aggregated information that allow us to better understand our customers and visitors.

 

You have a number of options to control or limit how we and our partners use cookies:

You can opt out of Google Analytics.

 

For more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

 

To learn how to manage privacy and storage settings for Flash cookies, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

 

Further information about deleting and blocking cookies can be found at http://www.allaboutcookies.org.

SENSITIVE DATA

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests, namely to grow our business.

 

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

 

You can ask us our third parties to stop sending you marketing messages at any time simply by unsubscribing from emails via the unsubscribe button which can be found at the bottom of each email or by sending info@enablingadaptations.com an email with your request to stop receiving emails.

 

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

DISCLOSURE OF YOUR PERSONAL DATA

 

We may have to share your personal data with the parties set out below:

 

Service providers who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers.

Government bodies that require us to report processing activities.

3rd party technology platforms and advertisers that support the running and growth of Enabling Adaptations Inc.

 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

WHAT WE USE YOUR INFORMATION FOR

We use collected information in a variety of ways, including to: process and fulfil purchases of products and services and keep you informed about the status of the same; communicate about and administer our products, services, events, online webinars, podcasts, programs  and promotions (such as by sending transactional emails about your purchases and/or User Account, promotional materials, newsletters and other marketing communications); conduct and facilitate quizzes, forms, surveys, contests, promotions, and giveaways; create, administer and communicate with you about your User Account; respond to your inquiries, comments, and applications; conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand); operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products and services; managing our communications and customer relationships; and performing accounting and billing activities).

 

The legal basis for processing your personal information as described above will typically be one of the following:

 

Your consent; Performance of a contract with you or a relevant party; Our legitimate business interests; or Compliance with our legal obligations.

WHO WE SHARE YOUR INFORMATION WITH

Publicly Shared Information

 

Any information that you voluntarily choose to share in a public area of our Sites (for example, by posting a comment to a blog post, or a webinar chat) will be available to anyone who has access to that content.

 

To Company Employees and Contractors

 

We may share your personal information within the Company to our employees and contractors in order to deliver our services and products to you.

 

Third-Party Service Providers

 

We use third-party service providers to collect and process personal information from or about you on our behalf. Examples include data analysis, marketing and advertising services, email and hosting services, customer services and support, hosting User Accounts, processing credit card payments, and collecting customer research or satisfaction surveys. They have access to the personal information needed to perform their functions.

 

Online Advertising Services

 

We may use third-party advertising services, like Facebook® and Instagram®, to deliver advertising about our products and services on our Sites, as well as other websites and applications you use. The ads may be based on information we have collected (as outlined above) and information these advertising providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.

 

Analytic Services

 

We may use third-party browser and mobile analytics services like Google Analytics® on the Sites. These services use tools to help us analyse your use of the Sites, including information like the third-party website you arrive from, how often you visit, events within the Sites, usage and performance data, and purchasing behaviour. We use this data to improve the Sites and provide information, products and services that may be of interest to you.

 

Law Enforcement, Legal Process and Compliance

 

We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.

 

Change of Ownership

 

We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the information we share.

KEEPING YOUR INFORMATION SECURE

 

The transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Sites or over email; any transmission is at your own risk.

 

YOUR RIGHTS

 

You have rights in relation to the personal information we hold about you. Below is an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

 

Your Choices About the Use of Your Data

 

You can choose not to provide certain data to us, but you may not be able to use certain features of the Sites.

 

Marketing Email Communications: You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all marketing email messages from us or by contacting us at info@enablingadaptations.com.

 

Transactional or Service Email Communications: Some communications from us are considered transactional or service communications (for example, important account notifications, product updates, and billing information), and your Company products and services are provided to you upon the condition that you receive these communications from us.

 

If you do not wish to receive any transactional or service communications from us, you must cancel your User Account for Company products and services. To cancel your User Account, you can email info@enablingadaptations.com. You may still receive marketing communications from us even after you cancel your User Account unless you also opt-out of our marketing communications, as described above.

 

Navigation Information: You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.

 

Information from Third Parties: To manage the information we receive about you from a social media site or other third parties, you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this privacy policy and the information the third-party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third-party site will not apply to our use of the information we have collected directly through our Sites.

 

Cookies: To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages referenced above under “Automatically Collected Information through Tracking Technologies.”

Accessing, Updating, Transferring and Deleting Your Data

 

You can update your personal information as follows:

 

You can update your User Account information (if applicable) by logging into your User Account and updating your settings.

 

To update other data, please contact us at info@enablingadaptations.com. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required.

 

If you wish to access any personal information that we hold about you, or to request that we delete or transfer any information about you that we have obtained, you may contact us at info@enablingadaptations.com. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request.

 

Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

 

At any time, you may object to the processing of your personal information, on legitimate grounds, except if otherwise permitted by applicable law. If you believe that your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at info@enablingadaptations.com. You also may have a right to lodge a complaint with data protection authorities.

THIRD-PARTY SITES

 

The Sites may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Sites. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Sites. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

DATA TRANSFERS

 

In order for us to provide the products and services to you, your personal information will be stored and processed in Canada and the United States, depending on our vendors. Where data is shared with third-party data processors, your data will be captured, transferred, stored and processed in accordance with their policies, practices and in compliance with their local regulatory laws.

 

We reserve the right at our sole discretion to change our service providers. We will give you seven (7) days’ notice of any change of provider and we will inform you as to the new vendor.

 

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

 

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being customers.

 

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

OUR POLICY CONCERNING MINORS

Minors should not use the Sites. If we learn that we’ve collected personal data from a minor, we will take reasonable steps to delete it. Parents who believe that the Company may have collected personal information from a minor can submit a request that it be removed by contacting us at info@enablingadaptations.com.

 

The only exception for which a minor would use our Sites is to access Jane.app, our external practice management web-based program, with parental or guardian supervision only. Please refer to Jane.app for its privacy policy, terms of use, security and trust, and other relevant policies.

CHANGES AND UPDATES TO THIS POLICY

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available here, and indicate the date of the latest revision. Your continued use of the Sites after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

COOKIES

As you browse Enabling Adaptations Inc., advertising cookies will be placed on your computer so that we can understand what you are interested in. Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. To opt out of cookies, find and select the settings tab of your internet browser and click “block third party cookies and site data” or de-select the “accept cookies” box.

ORDERING PRODUCTS ON OUR SITES

We will request information from you on our order forms for purchase of products. To buy from us, you must provide contact information (like name and shipping/billing address) and financial information (like credit card number, expiration date, CVV). This information is used for billing purposes and to fill your orders. If we have trouble processing an order, we’ll use this information to contact you.

HOW DO WE PROTECT VISITOR INFORMATION?

We implement a variety of security measures to maintain the safety of your personal information. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. When you place orders or access your personal information, we offer the use of a secure server. All sensitive/credit information you supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases to be only accessed as stated above.

DO WE DISCLOSE THE INFORMATION WE COLLECT TO OUTSIDE PARTIES?

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice, except as described below. It does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

 

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

 

HOW CAN YOU OPT-OUT, REMOVE OR MODIFY INFORMATION YOU HAVE PROVIDED TO US?

To modify your email subscriptions, you can find an unsubscribe link at the bottom of each email. Please note that due to email production schedules you may receive any emails already in production. Please note that we may maintain information about an individual sales transaction in order to service that transaction and for record keeping.

THIRD PARTY LINKS

In an attempt to provide you with increased value, we may include third party links on our site. These linked sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these linked sites (including if a specific link does not work).

YOUR ACCESS TO AND CONTROL OVER INFORMATION

You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website:

 

See what data we have about you, if any.

Change/correct any data we have about you.

Have us delete any data we have about you.

Express any concern you have about our use of your data.

CHANGES TO OUR POLICY

If we decide to change our privacy policy, we will post those changes on this page. Policy changes will apply only to information collected after the date of the change.

ONLINE PRIVACY POLICY

This privacy policy refers only to information collected through our websites, and does not apply to information collected in person at events, coaching calls or social media.

 

YOUR CONSENT

In using our site, you agree to our Privacy Policy.

QUESTIONS AND FEEDBACK

We welcome your questions, comments, and concerns about privacy. Please send us any and all feedback pertaining to privacy, or any other issue via email at: info@enablingadaptations.com.

 

HOW TO CONTACT US

You can us with any questions or comments about the Privacy Policy at:

 

Email: info@enablingadaptations.com

 

Effective date: April 25, 2022