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Privacy Policy

Privacy Policy

LAST UPDATE OF THIS PRIVACY POLICY – March 6, 2020.

Definition

Kabookey 2™: A trademark of Guiding Star Communications and Consulting Inc. which refers to a platform (collection) of digital technology assets (“platform”) including apps for iPads and Android tablets, and a toolkit and web portal that is used for composing and publishing content to the apps, including a web native app. Among the tools in the Kabookey 2™ platform is the Kabookey Builder, a customized variant of the OASIS Web Content Management System, which is wholly owned by Sandbox Software Solutions Inc and used under license by Guiding Star Communications and Consulting Inc.

Introduction

Guiding Star Communications and Consulting Inc. (hereinafter referred to as “Guiding Star”) respects your right to privacy and we understand that, when you visit our website and use our products and services or otherwise interact with us (for example, by viewing our webinars), you prefer to control the way you share your personal information (“Personal Data”) and preferences. Guiding Star offers a wide range of products, including our web-based services, app-based services, and support services associated with Kabookey 2™. Guiding Star has licensed some elements of Kabookey 2™ from other vendors and service providers, and asserts its rights for their use through licenses and enforces this Privacy Policy to apply to all of Kabookey 2™. The term "Service” or “Services” means the websites and applications of Guiding Star, including www.guidingstarcc.com and www.kabookey.com, any other sites on which this Privacy Policy is posted, and any other Guiding Star application, service or product licensed, downloaded or otherwise accessed by you through third party sites or sources, including the products and services available through any of the foregoing.

By accessing and/or using any Guiding Star-controlled website or any Guiding Star Services, you are accepting the practices described in this Privacy Policy. 

You must be at least thirteen (13) years of age, or sixteen (16) years of age if you are located in the European Union, to create an account on any of our Services. If you are younger than eighteen (18) (or the age of legal majority where you live, you may use the Services only under the supervision of a parent or legal guardian who agrees to be bound by these Terms of Use. If you are a parent or legal guardian of a user under the age of eighteen (18), you agree to be fully responsible for the acts or omissions of such user in relation to any Guiding Star Services. For additional policies pertaining to children, please see the section on Children below.

The terms “we,” “us” and “our” refer to Guiding Star. The terms “user”, “you”, and “your” refer to visitors, customers and any other users of any Guiding Star Services, including Kabookey 2™.

Guiding Star provides this Privacy Policy ("Policy") to inform you of our practices with respect to the collection and use of your Personal Data.

Guiding Star complies with the Regulation 2016/679/EU of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”). Guiding Star acts as both a data controller and a data processor under GDPR.

Guiding Star has implemented the following requirements under the GDPR, including but not limited to:

  • A record of our Personal Data processing activities;
  • Adequate organizational and technical protection measures;
  • Request forms and internal instructions for Privacy by Design & Default, Data Portability, and Data Subject Rights like the Right to be Forgotten.

We collect information globally and primarily store that information on servers based in Canada. We may transfer, process, and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. The Personal Data of individuals from the EEA and Switzerland is stored and processed on servers based in Canada. We use the model contract clauses approved by the European Commission as a means of ensuring adequate protection when transferring data outside of the EEA and Switzerland. By incorporating model contract clauses into a contract established between the parties transferring data, personal data can be protected when transferred outside the EEA to countries which have not been deemed by the European Commission to adequately protect personal data.

Kabookey 2™ further complies with Canadian Federal and Provincial privacy laws and regulations including the Personal Information and Electronic Documents Act.

Agreement to this Policy

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this  Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

How Guiding Star may collect information about you in our role as data controller

We collect information about you and determine the purposes and means of processing your Personal Data in our role as data controller when you input it into the Services or otherwise provide it directly to us.

Site account and Profile Information: We collect information about you when you order Services from Guiding Star, including registering to create a site account at a web portal which leverages Kabookey 2™, creating or modifying your profile, setting preferences, and signing-up for or making purchases through the Services. We keep track of your preferences when you select settings within the Services.

Information you provide through our support centre: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

Subscription to Guiding Star newsletters and webinars. We collect information about you when you subscribe to our newsletters and webinars. You can set your communication preferences from your site account or opt-out at any time.

Information we collect automatically when you use the Services

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

Your use of the Services: We keep track of certain information about you when you interact with any of our Services. This information includes the features you use; information about the system configuration; time you spent using the Services; the links you click on; the type, size and filenames of attachments you upload to or download from the Services; frequently used search terms; and how you interact with others on the Services.

Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience.

Cookies: Guiding Star uses cookies to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookie Policy, which includes information on how to control or opt-out of the cookies and other tracking technologies.

Information we receive from other sources

We receive information about you from other Service users, from third-party services, and from our business partners.

Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned in a support ticket opened by someone else. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator may provide your contact information when they designate you as the billing or technical contact on your company's site account.

Guiding Star Partners: We work with a global network of partners who help us to market and promote our products, generate leads for us, and resell our products. Some of these partners provide consulting, training, and other services connected to our products. We receive information from these partners, such as contact information, company name, what Guiding Star products you have purchased or may be interested in, evaluation information you have provided, what events you have attended, and what country you are in.

Third-party Services: Our Services may use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, text files that are stored on your computer and enable analysis of your use of our Services. The information generated by the cookies about your use of our Services are usually transferred to a server of Google in the United States of America (US), and stored there. In case of activation of IP anonymization on our Services, your IP address from Google will be truncated within Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address is transmitted to a Google server in the US and shortened there. You can refuse the use of cookies by selecting the appropriate settings on your browser software. You can also prevent the data generated by the cookie and related to your use of the Website to Google and the processing of these data by Google, by clicking the following link (https://tools.google.com/dlpage/gaoptout), choosing the available browser plug-in and installing it.

What information Guiding Star may collect about you in our role as data controller

Guiding Star may collect the following information about you:

  • Your name, email address, phone number, company name, title and business/private address;
  • Your site account information at a site using Kabookey 2™ – such as Guiding Star Services you ordered, domain name registration information, the IP addresses assigned to you, the use of Guiding Star Services or any other information related to your site account;
  • Your contact with Guiding Star – such as a note or recording of a call you make to Guiding Star, a chat record when you engage in a chat session with Guiding Star, an email or letter you send to Guiding Star or other records of any contact you have with Guiding Star;
  • The email addresses of the users who receive the results of a test, quiz or exercise if the software product with this functionality uses the function of collecting user data with sending to an email address;
  • The email addresses of the users who pass tests, quizzes or exercises created using the software product with this functionality if the software product uses the function of collecting user data with sending to email addresses.
  • The email addresses of the users (instructors) who receive the results of the test, quiz or exercise of other users to review the test, quiz or exercise. You are responsible for submitting the correct email addresses while using this functionality;
  • Information provided by you to Guiding Star when you notify Guiding Star of a (suspected) breach of acceptable use of Guiding Star Services;
  • Your photo when you send us a testimonial and video footage of you when we record your video review about Kabookey 2™.

Why Guiding Star processes your personal information in our role as data controller

Guiding Star processes your Personal Data for the following purposes:

  • Processing of orders and provision of Services;
  • Sending test or exercise results to You or validators of the test or exercises;
  • Conducting market research, conducting retention and customer satisfaction surveys, conducting marketing activities (including through email newsletters, social media and onsite/offsite and online/offline advertisement), conducting sales activities (including analyzing your Personal Data and your use of Guiding Star Services for making (personalized) offers and quotes with the aim of entering into a customer relationship, and/or maintaining, renewing or expanding a customer relationship);
  • Communicating with customers (a) to provide information about Services of Guiding Star and affiliated companies, (b) to provide information about offers, orders, provision of Services, order status and payment, (c) to provide support and maintenance services, (d) to handle complaints, and (e) to answer questions from (potential) customers;
  • Investigating and processing suspected violations of acceptable use of Guiding Star Services;
  • Complying with statutory obligations, including (a) provision of data to authorized authorities in the context of criminal investigations, (b) complying with (applicable) data retention obligations, and (c) the provision to third parties of Personal Data concerning customers in connection with an infringement of these third parties’ rights.

How we share your personal information in our role as data controller

Guiding Star may share Personal Data about you with:

  • Partners or agents involved in delivering the Services;
  • Law enforcement agencies, regulatory organizations, courts or other public authorities to the extent required by law;
  • A Guiding Star customer, if you notify Guiding Star that this customer’s use of Guiding Star Services violates the acceptable use of Guiding Star Services or applicable law;
  • A third party that has claimed that your use of the Guiding Star Services violates the acceptable use of Guiding Star Services or applicable law (to the extent such sharing is required by law);
  • In certain situations, Guiding Star may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Guiding Star in its role as processor

Personal information and content you provide through Guiding Star web-based services. When customers and Guiding Star partners use Guiding Star web-based services to process Personal Data in their content, Guiding Star acts as a data processor. The customer of Guiding Star that owns an account in Guiding Star web-based services including Kaboookey 2™ will be responsible for determining the purposes and means of the processing of the content and any Personal Data provided by end-users of the account, and this Guiding Star customer (or its end users) will be the data controller in regards to such processing.

The owner of an account in Guiding Star web-based services has the right to update the email address associated with his account or deactivate an account by submitting a written request to info@guidingstarcc.com.

If at any time Guiding Star has access to Personal Data stored in the account owned by a Guiding Star customer, then Guiding Star shall be a data sub-processor, and any actions performed by Guiding Star in relation to such data shall be solely governed by the agreement concluded between us and the Guiding Star customer. Guiding Star offers a GDPR-compliant Data Processing Addendum (DPA) that incorporates Guiding Star’s commitments as data processor.

Legal bases for processing

If you are an individual in the European Economic Area (EEA) or Switzerland, we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. To process your information as described above, we rely on the following legal bases:

  • Performance of a contract: the use of your information is necessary to provide you the Services, customer support, and personalized features. If you order and use our Services, we will use your information to carry out our obligation to complete and administer that Services under the contract that we have with you;
  • Legitimate interests: the processing is necessary for the purposes of the legitimate interests pursued by us, namely for information security. We also want to provide you with the best suitable content via Kabookey 2™, to improve and promote our products and services and the content on our website, and for administrative, fraud detection and legal purposes;
  • Consent: we may rely on your consent to use your Personal Data for specific purposes, for example, for sending newsletters and for certain direct marketing purposes.

How we store and secure information we collect

Information storage. We use data hosting service providers in Canada to host the information we collect, and we use technical measures to secure your data.

Technical and organizational security procedures and data transfers. We observe reasonable procedures to prevent unauthorized access to and the misuse of Personal Data. We use appropriate business systems and procedures to protect and safeguard Personal Data. We also use security procedures and technical and physical restrictions for accessing and using the Personal Data on our servers. Only authorized personnel are permitted to access Personal Data in the course of their work.

For more information on where we store your information and our security measures, please contact us as provided in the Contact Us section below.

Because Guiding Star is a company with customers located in many different countries around the world, it is important that we comply with data privacy laws in many jurisdictions. In our role as data processor, we have implemented the model contractual clauses to enable the lawful transfer of Personal Data from the EEA and Switzerland to the United States. The Standard Contractual Clauses set out Guiding Star commitment to privacy and data protection when processing data in connection with the provision of products and services to our customers and partners, and dealing with the transfer of Personal Data outside the EEA and Switzerland in connection with the provision of such products and services. If you are a customer or partner that specifically requires the implementation of model contractual clauses directly with Guiding Star, where appropriate and where Guiding Star is a data processor for the customer or partner, please contact us as provided in the Contact Us section below.

How long we keep information (retention procedures)

Guiding Star will store your personal information for as long as necessary to perform the purposes of processing as stated in this Policy. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Guiding Star stores the email addresses of the users who receive the results of tests, quizzes or exercises for one (1) month in order to restore the results and send them to You or Your users. Guiding Star no longer uses this data: after a month retention period, all the data will be deleted.

Site account information: We retain your site account information for as long as your site account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

Information you share on the Services: If your site account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display the content you provided.

Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Guiding Star site account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

How you can access and control your information

Subject to some limits, you have certain rights regarding your Personal Data and the processing thereof. PLEASE NOTE THAT OUR CUSTOMERS CONTROL AND MAINTAIN ACCESS TO THEIR DATA THAT IS STORED BY GUIDING STAR, AND WE MAY NOT HAVE ACCESS TO THE DATA MAINTAINED BY OUR CUSTOMERS OR EVEN KNOW WHAT DATA IS BEING MAINTAINED.

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. If you are an end-user and the Services are administered for you by an administrator (see section "Notice to End Users" below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.

Your rights:

  • You can access and update your information in your site account at any time;
  • You can deactivate your site account if you no longer wish to use our Services;
  • You can request the information Guiding Star has collected about you;
  • You can request that we make changes to the Personal Data you have seen, but cannot change in your site account;
  • You have the right to obtain from us the erasure of your Personal Data (right to be forgotten);
  • In addition, you may, under certain circumstances, have the right to restriction of the processing of your Personal Data;
  • You have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data;
  • You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller when the processing is based on your consent or is necessary for the performance of a contract (the right to data portability);
  • You can opt-out of promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your site account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt-out of receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt-out of some notification messages in your site account settings;
  • You can refuse the use of cookies: relevant browser-based cookie controls are described in our Cookie Policy.

Guiding Star acknowledges that EU individuals have the right to access the personal information that we maintain about them. An EU individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to info@guidingstarcc.com. If requested to remove data, we will respond within a reasonable timeframe.

Consent and withdrawal of consent. You are entitled to withdraw your consent at any time by giving us notice. Upon receipt of a notice where your consent is withdrawn, we will without undue delay stop processing your Personal Data to the extent it is required under the law. Please use the contact information at the bottom of the page should you wish to withdraw your consent given under this privacy statement. To limit the use and disclosure of your personal information, please submit a written request to info@guidingstarcc.com.

Data Security Measures

Although we provide appropriate firewalls and protections, we cannot warrant the security of any Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we assume no liability or responsibility for it. You are required to be careful to avoid “phishing” scams, where someone may send you an e-mail that looks like it is from us asking for your Personal Information.

Third parties

Guiding Star Services may allow you to share information through social media (such as by logging in through a social media account or using a "Like" button") or contain links to social media services or other third parties. The use of these features and links are subject to the privacy policies of those companies and your settings on those services. Guiding Star has no control over, and is not responsible for, the information submitted to or collected by social networks or other third parties. We encourage you to review those third-party privacy policies to understand the way your information may be collected and handled by such third parties.

Chat and messaging

Guiding Star Services may operate message boards, data exchange functionalities, and/or chat tools where users can exchange ideas, submit questions for answer, and communicate with each other. When posting to a message board or chat area, the information is being made available to others in an online environment. Any information posted in such tools is the sole responsibility of the individual user.

Notice to end users

Our web-based services are intended for use by organizations. Where the web-based services are made available to you through an organization (e.g., your employer), that organization is the administrator of the web-based services and is responsible for the accounts in web-based services over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the web-based services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.

Administrators are able to:

  • reset your account password;
  • restrict, suspend or terminate your access to the web-based services;
  • access information in and about your account;
  • access or retain information stored as part of your account;
  • install or uninstall third-party apps or other integrations.

In some cases, administrators can also:

  • restrict, suspend or terminate your account access;
  • change the email address associated with your account;
  • change your information, including profile information;
  • restrict your ability to edit, restrict, modify, or delete information.

The administrator of the account in web-based services will assert administrative control over your account and use of the web-based services.

You will be able to change the email address associated with your account only upon the administrator’s approval.

Please contact your organization or refer to your administrator’s organizational policies for more information.

Children

Guiding Star Services are generally designed for users who are at least 13 years of age and older and therefore such Offerings generally do not knowingly collect or make use of "personal information" as defined in the Children’s Online Privacy Protection Act ("COPPA") from children under 13, except as consistent with applicable law.

Some Guiding Star Services may allow children under 13 to participate in certain activities or gain access to limited gameplay or features within an application, but these offerings are designed to collect only certain device identifiers from children under 13 and use those identifiers solely for purposes that support the internal operations of those offerings or as otherwise permitted by law. We do not knowingly allow children under 13 (16 in the EU) years old to register for an account or otherwise provide any personal information to us, and we do not collect or use personal information from children under 13 for targeted advertising purposes.

Guiding Star respects the privacy of parents and children and is committed to complying with COPPA. If a parent believes that his or her child has submitted personal information to Guiding Star, he or she can contact us via email at info@guidingstarcc.com, or postal mail at: Guiding Star Privacy Policy Department, P.O. Box 316, Atwood, ON N0G 1B0 CANADA. We will take steps to promptly delete the information upon learning that it relates to a child under the age of 13 (16 in the EU). We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children's use of online activities frequently.

Limitation of Liability

To the extent permissible under the law, we shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data, information, or other intangible losses (even if we have been advised of the possibility of such damages), arising out of this Privacy Policy.

Governing Law and Disputes

This Privacy Policy shall be construed and governed by the laws of Ontario, Canada without regard to principles of conflict of laws. Any dispute arising, between you and us shall be submitted to an arbitration to be conducted in Ontario, Canada in English language by a sole arbitrator (appointed by us), and the award made in pursuance thereof shall be binding. Subject to the arbitration provisions, you agree that the courts in Ontario, Canada shall have an exclusive jurisdiction over such disputes.

For any EU residents, this Privacy Policy shall be governed by the provisions of the GDPR.

Changes to this Policy

We may change this Policy from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

Contact Us

If you have questions or concerns about how your information is handled, please direct your inquiry to Guiding Star Solutions, Inc.

Guiding Star Communications and Consulting Inc.
130 John St., P.O. Box 316

Atwood, ON  N0G 1B0 CANADA

info@guidingstarcc.com

 

 

 

Guiding Star Cookie Policy

Effective Starting: March 1, 2020

Cookies are small text files that can be used by websites to make a user's experience more efficient. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site.

Necessary cookies cannot be deselected. Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Guiding Star uses necessary first-party cookies to provide functionality of a website and to recognize you across different Services and devices, and third-party cookies for analytics and content-sharing.

What cookies do we use?

We use necessary cookies and other technologies to improve and customize our products and websites ("the Services") and your experience; to allow you to access and use the Services without re-entering your username or password; to understand usage of our Services and the interests of our customers; to determine whether an email has been opened and acted upon.

Cookies we use include:

  1. First-party cookies
  • user input cookies to keep track of the user's input when filling online forms, shopping carts, etc., for the duration of a session, or persistent cookies limited to the duration of an operation such as purchase or trial;
  • user identification persistent cookies, to identify the user visited the website for the first time;
  • authentication cookies, to identify the user once he has logged in, for the duration of a session;
  • user interface customization cookies such as time zone and shopping cart status info, for the duration of a session (or slightly longer).
  1. Third-party cookies
  • social plug in content sharing cookies, for logged in members of a social network;
  • Google Analytics cookies to generate statistical data on how the visitor uses the website.

How do we use them?

Where strictly necessary. These cookies and other technologies are essential in order to enable the Services to provide the feature you have requested, such as remembering you have logged in.

For functionality. These cookies and similar technologies remember choices you make such as time zone and shopping cart info. We use these cookies to provide you with an experience more appropriate with your selections and to make your use of the Services more tailored.

For performance and analytics. These cookies and similar technologies collect information on how users interact with the Services and enable us to improve how the Services operate. For example, we use Google Analytics cookies to help us understand how visitors arrive at and browse our products, services and website to identify areas for improvement such as navigation, user experience, and marketing campaigns.

Social media cookies. These cookies are used when you share information using a social media sharing button or “like” button on our websites or you link your account or engage with our content on or through a social media site. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

How can you opt-out?

To opt-out of our use of cookies, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use our Services.

Updates to this Cookie Policy

This Cookie Policy may be updated from time to time. If we make any changes, we will notify you by revising the "effective starting" date at the top of this notice.