Welcome to SOEMO, our website at www.guidinglightco.com and/or our iOS and Android mobile application. We (“Guiding Light Education Company Inc”, “we”, “us”, or “our”) understand that anyone who shares data on the Internet wants to be sure that their data does not fall into the wrong hands and that’s why we take great care to protect your data. Doing so, we follow Canada`s Personal Information Protection and Electronic Documents Act (PIPEDA) and EU`s General Data Protection Regulation (GDPR).
What is Personal Data?
Personal data is all data that can be related to you personally, e.g., name, e-mail addresses, user behavior. The personal data of users processed within the scope of our website includes inventory data (e.g., names, e-mail addresses and addresses), usage data (e.g., the websites visited on our website, interest in our products) and content data (e.g., information in messages and forms you fill in).
Who is responsible?
Responsible for the collection and processing of personal data is:
Guiding Light Education Company Inc
PO BOX 99900 KM 878 902 RPO HEADON, BURLINGTON, ONTARIO L7M 0W6
E-Mail: hello@guidinglightco.com.
What do we process your data for (purpose of processing) and on what legal basis?
We process personal data in accordance with the PIPEDA and the GDPR:
- For the fulfilment of contractual obligations,
- Personal data is processed for the purpose of providing the services,
- The purposes of the data processing are primarily based on the services.
- Within the framework of our legitimate interests
Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples:
- Ensuring IT security and IT operations,
- Measures for business management and further development of services,
- Defense against third-party claims and enforcement of own claims.
- Based on your consent
- Insofar as you have given us your consent to process personal data for certain purposes, passing on data to third parties, sending newsletters, advertising etc., this processing is lawful on the basis of your consent.
- Consent given can be revoked at any time. Please note that the revocation is only effective for the future. Processing that took place before the revocation is not affected by this.
What data protection rights do I have?
Every data subject has
- the right to information,
- the right to rectification,
- the right to deletion,
- the right to restriction of processing, and
- the right to data portability under Art. 20 GDPR.
Further, you can revoke consent, in principle with effect for the future.
Furthermore, you have the right to lodge a complaint with a data protection supervisory authority. The Office of the Privacy Commissioner of Canada (OPC) is the Canadian relevant authority in matters of data protection. You have the right to make a complaint at any time to the OPC (www.priv.gc.ca/en). We would, however, appreciate the chance to deal with your concerns before you approach the OPC so please contact us in the first instance.
Finally, you also have a right to object. This applies, on grounds relating to data processing on the basis of our legitimate interest and also to profiling.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate reasons for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request to us in writing. Should you withdraw your consent to the collection, use or disclosure of your Personal Data, it may impact our ability to proceed with your transactions, agreements, or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.
Categories of personal data processed
We process the following categories of personal data:
- Customer data:
Name, email address, telephone number, billing address, payment methods and payment confirmations.
- Product data:
Products that you last purchased; Products that you placed in your shopping cart;
The advertisement links or newsletter links through which you were redirected to our website.
- Device Data
Online Identifiers and IP addresses.
Processing of special categories of data
No special categories of data are processed.
Automated Decision Making
Automated decision making within the meaning of the PIPEDA and GDPR is not used.
Contacting us
If you contact us per e-mail or social media, we process the following data from you for the purpose of processing and handling your enquiry: Name, contact details -if provided by you- and your message. The legal basis of the data processing is our obligation to fulfil the contract and/or to fulfil our pre-contractual obligations and/or our legitimate interest in processing your enquiry.
Subscriptions and Orders
If you buy a subscription or order products and printables from us, the processing is done to fulfil the contractual service such as delivery to your e-mail account, payment processing and billing.
The sales contract with you is the legal basis for this processing. We will also process your data to the extent required by law to fulfil our archiving and retention obligations under Canadian commercial and tax law. The provision of this personal data and order data is necessary for the conclusion of the contract.
The provision of bank details is subject to our payment processors Stripe for our website and Google Play and Apple Store for purchases in the App. We do not collect or store payment information or bank details ourselves but receive payment confirmation statements of our processors. For further information, please refer to the relevant providers privacy policy by clicking on the above links.
In addition, we may use your data for direct advertising - i.e., to send you information about our products, services and promotions. You can object to the use of your data for the purpose of advertising at any time, using the above contact details.
The duration of processing depends on the purpose of fulfilling the contract and the associated further legal requirements for storage and provision of evidence. For direct advertising, we use the data as long as you have not objected.
Registration
If you register on our website or the App, we process the data provided for this purpose in order to provide you with the services and the account function. The mandatory information requested is necessary for registration, as you can place orders and access our services and the mandatory information requested during registration is a prerequisite for fulfilment of the contract you enter with us.
In the context of your account, we process as part of our contractual service your name and e-mail address. The contract with you is thus the legal basis for this processing We will also process your data to the extent required by law to fulfil our archiving and retention obligations under Canadian commercial and tax law. The provision of personal data and order data is necessary for the conclusion of the contract and the creation of your account.
In addition, we may use your data for direct advertising - i.e., to send you information about our products, services and promotions. You can object to the use of your data for the purpose of advertising at any time, using the above contact details.
The duration of processing depends on the purpose of fulfilling the contract and the associated further legal requirements for storage and provision of evidence. For direct advertising, we use the data as long as you have not objected.
Use of our website
When you call up our website, our web server records the domain name or IP address of your computer, the file name and the URL that was requested, as well as the http response code and, if applicable, the URL referring to our website. This procedure is common for technical reasons and necessary to enable the use of our website. In this regard, we are supported by our technical service providers, which we use as processors. The above-mentioned data is logged and used for the purpose of defending against unlawful use or attempted attacks on our web server. A combination of this data with other data sources does not take place. However, we reserve the right to statistically evaluate anonymized data records. The data will be deleted after 6 months.
Use of cookies
We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.
Use of our App
The App can be downloaded from the "Google Playstore" and the "Apple App Store". Downloading the App may require prior registration with the respective App Store and/or installation of the respective App Store software.
- 1) Installation of the App via the Google Playstore.
You may use the Google service "Google Play" of Google Inc, to install the App. As far as we are aware, Google collects and processes the following data: License verification, network access, network connection, WLAN connections and location information.
It cannot be ruled out that Google also transfers the information to a server in a third country. We have no influence on which personal data Google processes during your registration and the provision of downloads in the respective app store and app store software. Google as the operator of the Google Play Store is solely responsible for this.
- 2) App installation via the Apple App Store.
You may use the Apple app service "App Store", a service of Apple Inc, to install the App. As far as we are aware, Apple collects and processes the following data: Device identifiers, IP addresses and location information.
It cannot be excluded that Apple also transmits the information to a server in a third country. We have no influence on which personal data Apple processes during your registration and the provision of downloads in the respective App Store and the App Store Software. In this respect, Apple is solely responsible as the operator of the Apple App Store.
3) Starting the AppEvery time you start the App, your data is synchronized, and your device communicates with our server through a signed token. The transmission takes place automatically and is a prerequisite for the secure functioning of the App and is therefore mandatory.
- 4) General app accesses
As with every server request, information such as IP address, user agent, etc. is transmitted and stored anonymously for 30 days in the server log. The provision of personal data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are also not obliged to provide the personal data. However, failure to provide the data could result in you not being able to use our App or not being able to use it to its full extent.
- 5) Network access data
The provision of network access data is necessary if you wish to make full use of our App. However, failure to provide this data could result in you not being able to use our App or not being able to use it to its full extent. Your data will be treated confidentially by us and deleted if you revoke the rights of use, or they are no longer required for the provision of services and there is no legal obligation to retain them.
- 6) Push messages
When you use the app, you will receive so-called push messages from us using the Google Firebase Tool, even if you are not currently using the app. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device.
- 7) Device information
Google and Apple may collect information from and about the device(s) you use to access our App, including hardware and software information such as IP address, device ID and type, device-specific and App settings and properties, App crashes, advertising IDs, information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope and compass.
- 8) Authorizations and access
We may request access or permission from your mobile device for certain features (internet, vibration, storage, file manager and push notifications). The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can change your permissions at any time via the settings menu of your device.
- 9) Uninstall
You can stop the collection of data by the App by uninstalling it using the standard uninstall procedure for your device.
Newsletter subscription
If you subscribe to our newsletter, you consent to us informing you regularly by e-mail about current and new offers and services as well as information from us about our services. You can revoke your consent at any time, by clicking on the unsubscribe link in each newsletter or by contacting us using the contact details provided above. When you register for the newsletter, we collect your e-mail address. Your e-mail address will be passed on to our service providers for newsletter dispatch, which we use as order processors. You will receive another confirmation e-mail to confirm your consent (so-called double opt-in procedure.) We will use your data until you revoke your consent. A revocation does not affect the lawfulness of the processing of your personal customer and health data carried out on the basis of the consent until the revocation. This consent is voluntary, you can order from us regardless of the consent given.
Is there an obligation for me to provide data?
Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.
Data Security
We secure our website and App and other systems through appropriate technical and organizational measures against loss, destruction, access, modification, or distribution of your data by unauthorized persons. However, and despite regular checks, complete protection against all dangers is not possible.
Our website and App use the industry standard SSL (Secure Sockets Layer) for encryption. This ensures the confidentiality of your personal information over the Internet. You can tell whether encrypted transmission is taking place by the closed key/lock symbol in your browser display.
Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
Passing on of data Your personal data will only be passed on to third parties,
- if you have given your express consent to this;
- if the disclosure is necessary for the fulfilment of contractual obligations;
- if we are legally obligated to disclose the data;
- if the disclosure of the data is in the public interest;
- if the disclosure of the data is necessary for the protection of our legitimate interests or the legitimate interests of a third party, unless your interests in the protection of your data override these interests.
Duration of storage of personal data
Your data will be stored by us for as long as it is needed for the respective purposes underlying the processing. Beyond that, we only store data insofar as we are legally obligated to do so, e.g., due to statutory retention obligations.
Accuracy
We endeavor to ensure that all decisions involving your Personal Information are based upon accurate and timely information. However, we rely on you to disclose all relevant information to us and to inform us of any changes in your Personal Information. As such, please disclose all relevant information necessary for us to provide services to you and ensure all information submitted to us is up-to-date, complete, and accurate. Kindly inform us promptly if there are any changes in your Personal Information.
Integration of third-party services and content
Within our website and App, we use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (hereinafter uniformly referred to as "content").
This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.
We endeavor to only use content whose respective providers only use the IP address to deliver the content.
Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our website, as well as being linked to such information from other sources.
The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:
- Fonts: Google Font API by Google Inc
- Content Management System and eCommerce: Shopify
- Webhosting: GoDaddy
- Newsletter: Convertkit
Validity and questions
This privacy and cookie policy is valid as of Wednesday, November 16, 2022. It is the current and valid version of our privacy policy. However, we point out that from time to time due to actual or legal changes a revision to this privacy policy may be necessary.
If you have any data protection questions enforce your rights or withdraw your consent, please feel free to contact us using the details provided above.
