This policy and the additional documents referred to within, establish the basis on which we process any Personal Data collected, including that from Data Subjects, as well as data provided by said Subjects or other sources. Data users are obliged to comply with this policy when Processing Personal Data on our behalf. Any breach of this policy may result in disciplinary action.
Users – all living identifiable individuals for whom we hold Personal Data. A User need not be an EU national or resident. All Users have legal rights with regards to their personal information.
Personal Data – data relation to a living individual who can be identified, directly or indirectly, from said data and/or other information in our possession. Personal Data can be factual (i.e. a name, address, or date of birth) or it can be an opinion about that person, their actions, and behavior.
Data Controller – people who, or organizations which, determine the purposes for and manner in which any Personal Data is processed. They are responsible for establishing practices and policies in line with GDPR.
Data User – employees, agents, and contractors whose work involves processing Personal Data. Data Users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.
Data Processors – any person or organization that processes Personal Data on our behalf and on our instructions. Employees of Data Controllers are excluded from this definition. However, suppliers that handle Personal Data on our behalf would be included.
Website – our website at https://www.itbestpath.com/
Processing – any activity or set of activities performed on Personal Data or sets of Personal Data, whether or not by automated means. This includes obtaining, recording, or holding data. It also pertains to carrying out any operation or set of operations with the data, including organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring Personal Data to third parties.
Profiling – the automated Processing of Personal Data performed by a Data User to evaluate personal aspects related to a natural person. In particular, to analyze or predict aspects concerning that natural person, such as their economic situation, personal preferences, interests, reliability, behavior, locations, or movements.
Services – (i) access to the relevant ‘IT BEST-PATH’ applications provided via the ‘IT BEST-PATH’ site or another designated website or IP address and/or (ii) ancillary online or offline products and services provided or licensed to Users, by ‘IT BEST-PATH’.
Data We Collect
‘IT BEST-PATH’ values your trust and adheres to ethical standards in gathering, using, and safeguarding any information you provide. We collect data from you via three primary sources; data voluntarily give directly from you, data collected through automated means and services, and data from third-party providers.
We collect and process the following personal information from you:
Data You Provide to Us
We collect and store information that you provide to us through a variety of means:
-‘IT BEST-PATH’ Website
-Customer Service Representatives
-Marketing Promotions (such as contests and sweepstakes)
Any interaction we share results in the collection of data. While you are never required to provide personal information within any confines of the ‘IT BEST-PATH’ experience, choosing to withhold data does limit the opportunities available to you. In order to be an active participant within ‘IT BEST-PATH’, certain personal information must be provided.
Data Collected Through Automated Means
We collect and store unidentifiable personal information automatically whenever you interact with us. That is, information pertaining to you that would not be useful in identifying you personally. For example, we may collect your Internet Protocol (IP) address, browser information, and reference site domain name when you visit our website. As you browse the Site, we collect information about the individual web pages or products you view, what websites or search terms referred you to us, and how you interact with the site in general. Then, we would analyze this data for preferences, trends, and site usage statistics. This automatically-collected data is referred to as “Device Information”.
We also collect information by using cookies, web beacons, and other related technologies. “Cookies” are small text files that a website sends to a user’s hard drive through the browser, for data storage. Most browsers accept cookies automatically. However, you are allowed to disable them. By doing so, you may not be able to take full advantage of everything ‘IT BEST-PATH’ has to offer. We recommend that you leave cookies “turned on”, helping us provide you with an optimal experience.
Other technologies, such as web beacons, log files, tags, and pixels also come into play. Log files track actions that occur on our site and collects data that includes your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. Web beacons, tags, and pixels are electronic files used to record information about how you browse our site.
-Customize account pages for individuals
-Track user visits and account features
-Determine which features and pages are requested or visited most frequently
-Save your password so you don’t have to provide it each time you visit the site
We use third-party companies to provide Internet data hosting, which helps us measure and determine how visitors use our website, thereby showing us the effectiveness of our website and promotions. As a result, we can consistently improve and optimize our website, as well as the products and Services we offer.
Third-party companies that we utilize include Google AdSense Advertising, Recurly, and Hubspot.
Both Recurly, Inc and Hubspot, Inc are used to enhance the ‘IT BEST-PATH’ Site experience, via billing, marketing, and emailing services.
We also use third-party companies to showcase advertisements (such as banners or links) on our behalf across the Internet. These companies use tracking technologies (including cookies and pixel tags) to collect non-identifiable information about your visits to our website. They also take note of your interactions with our products and Services in order to provide tailored ads based on your interests. Therefore, they’re “remarketing” on our behalf and on behalf of other advertises across the Internet.
In that same regard, we utilize third-party audience data (such as age, gender, and interests) to better understand our audience and market to them effectively. We do not use or associate personally identifiable information with remarketing lists, cookies, data feeds, or other anonymous identifiers.
Additionally, some of our email communications to you may include a “click-through URL” linked to a particular page on our Site. By clicking on one of these URLs, you will automatically enter our website and we may collect information related to the “click-through”. You may avoid having this information collected by not clicking on the URL links in our email correspondence.
We also use a variety of analytics tools in our Bootcamps for operational and marketing purposes, such as measuring and analyzing traffic patterns. These tools may collect data from sensors including video cameras, smartphone detectors, Wi-Fi networks, or other devices. Again, this allows us to improve your Bootcamp experience.
Data Collected from Other Sources
We may collect information about you from third-party sources. This would be information that is publicly available. For example, any information you submit in a public forum (such as a blog, chat room, or social networking site) can be read, collected, and used by us and others. This information is most often used to personalize your experience on our Site. Remember, you are responsible for the information you choose to submit in these areas.
We do not sell, trade, or otherwise transfer your Personally Identifiable Information to outside parties, unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users. These parties agree to and work under a confidentiality agreement. We may also release information when it is appropriate to comply with the law, enforce our Site policies, or protect ours or others’ rights, property, or safety.
Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. However, we do not include or offer third-party products or services on our website.
How We Use Your Data
Order Information is data we collect generally to fulfill any orders placed through our Site. This includes processing your payment information, arranging for shipping, and providing you with invoices and/or confirmations. Additionally, we use this Order Information to:
-Communicate with you
-Screen our orders for potential risk or fraud
-Provide you with information or advertising (with regards to your preferences)
We use collected Device Information to screen for potential risks and fraud and, more generally, to improve and optimize our Site.
Providing for Our Websites
Managing User Registrations
If you have registered for an account with us, we process your Personal Data. We manage your user account for the purpose of performing our contract with you, according to applicable terms of service.
Handling Contact and User Support Requests
If you fill out a “Contact Me” web form, request user support, or reach out to us by any other means, we process your Personal Data. Again, this is to perform our contract with you to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.
Managing Event Registrations and Attendance
We process your Personal Data to plan and host events or webinars you have registered for or that you attend. This includes sending related communications to you, to perform our contract with you.
Managing Contests or Promotions
If you register for a contest or promotion, we process your Personal Data to perform our contract with you. Some contests or promotions have additional rules containing information about how we will process your Personal Data.
If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments. We do this to the extent that it is necessary to complete a transaction and perform our contract with you.
Developing and Improving Our Services
We process your Personal Data to analyze trends and track your usage of our websites and interactions with your emails. This is done to the extent it is necessary for our legitimate interest in developing and improving our websites. It also allows us to provide our users with more relevant and interesting content.
Sending Marketing Communications
We will process your Personal Data to send you marketing information, product recommendations, and other non-transactional communications (e.g. marketing newsletters, telemarketing calls, SMS, or push notifications). This content involving us, our affiliates, and our partners includes information about our products, promotions, or events as necessary for our legitimate interest in conducting direct marketing. It is also to the extent you have provided your prior consent.
Complying with Legal Obligations
We process your Personal Data when cooperating with public and government authorities, courts, or regulators. This is done in accordance with our legal obligations under applicable laws to the extent that it protects our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites. This also includes the protection of personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, and court orders, legal processes, or to respond to lawful requests.
Tailor Recommendations for Content
We process your Personal Data to analyze recommendations best suited for you. This allows us to provide content that can guide you on a more direct path, thus enabling you to achieve your educational goals faster and more efficiently.
Solicit Feedback From Users
We will process your Personal Data to help identify core users that can help ‘IT BEST-PATH’ receive feedback regarding our Services. This helps us to better understand what our users are looking for and how we can best serve them.
Sharing Your Personal Data
We share your Personal Information with third parties to help us utilize it as described above. This includes providing you with targeted advertisements or marketing communications we believe may be of interest to you. Visit the Network Advertising Initiative’s educational page for more information on how targeted advertising works. You may opt-out of targeted advertising on Facebook, Google, Bing, and through the Digital Advertising Alliance.
We share your data with:
-Contracted service providers, such as Shopify and Google Analytics. These platforms provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support, and data enrichment. We use these services for those purposes and pursuant to the legal bases described above.
-Sponsors of contests or promotions for which you register.
-Third-party social media networks and advertising networks and websites. They usually act as separate controllers, allowing ‘IT BEST-PATH’ to market and advertise on third-party platforms and websites.
-Affiliates within the ‘IT BEST-PATH’ corporate group, as well as companies acquired in the future which would then become part of the ‘IT BEST-PATH’ corporate group. Data is shared to the extent that it is necessary to fulfill a request you have submitted via our Site, be it for customer support, marketing, technical operations, or account management purposes.
We will use reasonable efforts, in accordance with applicable laws, to notify you of any transfer of Personal Data to unaffiliated third-parties in the event of the following:
-A merger, reorganization, dissolution, or other fundamental corporate change.
-The sale of a website or business unit.
-The acquisition of a portion of our business, assets, or stock.
Finally, we may also share your Personal Information to comply with applicable laws and regulations. This would include responding to a subpoena, a search warrant, or other lawful request for information we receive, or to otherwise protect our rights.
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
The security of your information is important to us. We use reasonable administrative, logical, physical, and managerial measures to safeguard your personal information against loss, theft, and unauthorized access, use, and modification. We have instituted security procedures and measures to protect our servers and networks that store personal information. Unfortunately, no one can guarantee the complete security of any information being shared over the Internet. Therefore, we cannot ensure or warrant total security of any information. In order to help protect personal information you provide to us, take these actions:
-Do not share your password or account information with others
-Use a secure web browser
-Change your password frequently
If you wish to make changes to your password and account, or if you become aware of any loss, theft, or unauthorized use of your password, please contact us as soon as possible. Contact information can be found below.
How Long do we Keep Your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of the collection. When you place an order through the Site, we will maintain your order information for our records unless and until you ask us to delete this information. We determine the appropriate retention period for Personal Data based on the amount, nature, and sensitivity of the data. We also take into account the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means.
After the expiration of the applicable retention periods, your Personal Data will be deleted. If, for technical reasons, there is any data we are unable to delete entirely from our systems, we will take appropriate measures to prevent any further use of such data.
Your Choices About the Use of Your Data
You can choose to not provide certain data to us. However, as a result, you may not be able to use certain features or Services provided by ‘IT BEST-PATH’.
To stop receiving promotional communications from ‘IT BEST-PATH’, you may opt out by using the Unsubscribe link attached to the content. Note that regardless of your email preference settings, we will send you transactional messages regarding our Services. This includes administrative confirmations, order confirmations, important updates regarding our Services, and notices about our policies.
If you have any questions about your data, our use of it, or your rights, contact us at email@example.com.
Accessing, Updating, and Deleting Your Personal Data
You may log into your account at any time to provide and update your Personal Data.
For ease of access to your account, use the “Remember me on this device” function when you log into our Site. This function uses technology that enables us to provide direct account access and to help administer our Services without requiring reentry of any password or other user identification when your browser revisits the Site.
To remove access to your ‘IT BEST-PATH’ account from your devices, your ‘IT BEST-PATH’ settings can be deleted. Options and steps vary and may not be available on all devices. When possible, users of public or shared devices should out at the completion of each visit. If you sell or return a computer, be sure to log out of your account. If you do not maintain the security of your password or device, or fail to log out of or deactivate your device, subsequent users may be able to access your account. Additionally, they would have access to your personal information.
If you have any issues terminating your account, email us at firstname.lastname@example.org.
Please note: even after your account is terminated, some or all of your data may still be visible to others. This includes, without limitation, any data that has been;
-Copied, stored, or disseminated by other users (including in course comment).
-Shared or disseminated by you or others (including in your shared content).
-Posted to a third-party platform.
To request to access, correct, or delete your personal data, please contact us either via email at email@example.com or mail at:
IT BEST-PATH Consulting & Services Inc.
5713 Harold St, Vancouver, BC, CANADA
Please allow up to 30 days for a response. For your protection, we may require that your request be sent through the email address associated with your account. We may also need to verify your identity before implementing your request. Please note; we retain certain data where we have a lawful basis to do so. This includes data kept for mandatory record-keeping, as well as to complete transactions.
Our Policy Concerning Minors
Children under 13 are not allowed to use our Services. Children in the European Economic Area under 16 are not allowed to use our Services. If we learn that we’ve collected Personal Data from a minor under those ages, we will take reasonable steps to delete it.
Please note that our Site is not intended for individuals under the age of 16.
Parents who believe that we may have collected Personal Data from a child can submit a request that it be removed to firstname.lastname@example.org.
Updates and Contact Information
Contacting ‘IT BEST-PATH’
By Email: email@example.com
Attn: ‘IT BEST-PATH’ Customer Service
IT BEST-PATH Consulting & Services Inc.
5713 Harold St, Vancouver, BC, CANADA
IT BEST-PATH Consulting & Services Inc.
5713 Harold St, Vancouver, BC, CANADA