Last Updated: August 11, 2018.
1. Your Consent
2. Data Controller
For purposes of the General Data Protection Regulation (the “GDPR”), we are the data controller for the purpose of data protection law, in respect of your personal information collected and used through your use of the website, products and services. This is because we dictate the purpose for which your personal information is used and how we use your personal information.
3. Personal Information Defined
4. Personal Information CFI Collects
We collect personal information about you in the course of providing the websites, blogs, apps (including but not limited to messaging services), products and services and our correspondence with you. The information may include the following:
|Personal contact information||Name, personal address, personal email address and personal telephone number|
|Business contact information||Name, business address, business email address and business telephone number|
|Account information||Username and account preferences|
|Payment information||Payment card number (credit or debit card), bank account number, billing address or other financial account numbers and account details|
|Financial aid application information||Contact information, link to social media profile, education and employment information, annual income, country of residence, aid preferences, answers to questions about your financial situation and academic or professional achievements|
|Course and enrolment information||Online registration information, record of attendance information and assessments|
|Social Media||Information relating to your social media profiles, including (but not limited to) LinkedIn|
|Marketing preferences, marketing activities and customer feedback||Marketing preferences, or responses to voluntary customer satisfaction surveysTo improve our marketing communications, we may collect information about interaction with, and responses to, our marketing communicationsReviews and endorsements provided regarding our courses|
|Other information you provide to us||For example, if you write a review of our products, submit a “Contact Us” form or provide other information to us in the course of your use of our websites, products or services|
5. How CFI Collects Information
(a) Information You Provide
You may be asked to voluntarily give your personal information to CFI when you interact with CFI. This information may be provided:
- in the course of communications between you and us (including by phone, email, chat, in person, via social media, website or otherwise);
- when you register for an account;
- when request information about or use a product or service provided by us;
- when you subscribe to a newsletter;
- when you attend tradeshows and other events; and
- when you report a problem with our websites, products our services.
In certain circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with CFI or otherwise receive the full benefit of the desired product or service.
If you give CFI the personal information of another individual, then you are solely responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to CFI and to CFI’s use, disclosure and retention of the personal information.
(b) Automated Collection
CFI may automatically collect certain information regarding your use of CFI’s websites, such as the dates and times that you use the websites, the browsers, operating systems, software and devices that you use to access the websites and details of your use of the websites.
CFI’s websites, email messages and advertisements may use technologies (e.g. cookies, web beacons, tokens, pixels or tags) to collect information that assists CFI to improve its products, services, customer communications and advertising and to prevent fraud. CFI may use information collected through technological means to recognize you as a user of CFI’s websites, to facilitate and improve your use of CFI’s websites, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of a website. More information about cookies used for interest-based advertising is set out in section 4(c) below.
- help remember and process the items in the shopping cart;
- understand and save user’s preferences for future visits;
- keep track of advertisements; and
- compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You may choose to decline or disable cookies if your web browser permits, but doing so may affect your ability to access or use certain features of CFI’s websites. However, you will still be able to place orders.
(d) Internet-Based Advertising
(e) Information from Other Sources
CFI may collect personal information from various publicly available sources and other third parties that are lawfully entitled to share your personal information with CFI.
CFI may combine your personal information collected by CFI through various sources.
6. How CFI Uses Personal Information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
- to comply with our legal and regulatory obligations;
- for our legitimate interests (see below) or those of a third party;
- for the performance of our contract with you or to take steps at your request before entering into a contract; or
- you have given consent.
A legitimate interest is when we have a business or commercial reason to use your personal information, so long as this is not overridden by your own rights and interests. Where we rely on our legitimate business interests or those legitimate interests of a third party to justify the purposes for using your personal information, this will include:
- pursuit of our commercial activities and objectives, or those of a third party;
- compliance with applicable legal and regulatory obligations and any codes of conduct;
- improvement and development of our business operations and service offering, or those of a third party; or
- protection of our business, shareholders, employees and customers, or those of a third party.
(b) Purpose and Legal Basis
|To administer your relationship with CFI, including to contact and correspond with you regarding those matters||For our legitimate business interests (i.e. the provision of the websites, products and services)|
|To facilitate your interactions and transactions with CFI||For our legitimate business interests (i.e. the provision of the websites, products and services)|
|To provide you with the websites, products and services||For our legitimate business interests (i.e. the provision of the websites, products and services), and depending on the circumstances, to perform a contract between you and us|
|To process your application for financial aid||For our legitimate business interests (i.e. the provision of our products and services)|
|To process and respond to your inquiries, requests and other communications||For our legitimate business interests (i.e. the provision of the websites, products and services)|
|To notify you about changes to the websites or the products and services||For our legitimate business interests (i.e. the provision of the websites, products and services)|
|To audit and monitor the use of the websites||For our legitimate business interests (i.e. the provision of the websites, products and services, as well as to improve and monitor the security of the websites) or we may request your consent in certain circumstances where we are required to do so by law (e.g., in relation to our use of certain cookies)|
|To maintain, protect and improve CFI’s products and services and to develop new products and services||For our legitimate business interests (i.e. the provision and improvement of the products and our services)|
|To manage complaints, feedback and queries||For our legitimate business interests (i.e. the provision and improvement of the websites, products and services)|
|To administer and facilitate your participation in contests and promotions related to CFI||For our legitimate business interests (i.e. the promotion of the websites, products and services), and depending on the circumstances, to perform a contract between you and us|
|To carry out market research and analysis||For our legitimate business interests (i.e. the provision, improvement and promotion of the websites, products and our services)|
|To carry out satisfaction surveys and analysis||For our legitimate business interests (i.e. the provision, improvement and promotion of the websites, products and our services)|
|To provide you with information (including by email and other electronic messages) regarding CFI and its business, products and services and products and services offered by other businesses, to the extent permitted by applicable law and in accordance with your preferences as indicated when you entered into any agreement with us, including any marketing consent preferences||Depending on the method of communication, this processing may be carried out with your consent or in accordance with our legitimate business interests to process your information for direct marketing purposes|
|To comply with any legal or regulatory obligations (including in connection with a court order) and to protect and enforce CFI’s legal rights, interests and remedies to protect the business operations and customers of CFI or other persons||For our legitimate business interests and for compliance with legal obligations to which we are subject|
|To enforce or apply the agreements concerning you (including agreements between you and us)||For our legitimate business interests and for compliance with legal obligations to which we are subject|
(c) How We Use Automated Decision Making When We Process Your Personal Information.
To help us assess your suitability for financial aid, decisions will be made about you using automated computer software on a system. This is known as automated decision making.
The systems apply pre-defined logic programming and criteria to make a decision and these decisions do not require human input.
You have the right to challenge any automated decision with us directly. You can object to an automated decision, ask that we do not make automated decisions about you and ask that a person reviews it. If you want to know more details about your rights, please see section 17(d) below.
7. How CFI Discloses and Shares Personal Information
(b) Specific Consents
CFI may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with CFI.
(d) Referred Transactions
(e) Suppliers and Service Providers
(f) Professional Advisers
CFI may disclose your personal information to our professional advisers including accountants, lawyers and other professional advisers that assist us in carrying out our business activities.
(g) Law Enforcement/Legal Disclosures
(h) Business Transactions
(i) Information that You Share
You may use CFI’s products and services (including membership in the Global Corporate Finance Society by creating a Global Corporate Finance Society member profile) to share your personal information and other information and content with other users of CFI’s products and services, including other Global Corporate Finance Society members (collectively “CFI Users”). When you do so, the information and content that you share can be read, collected, used, retained and disclosed by other CFI Users and may be publicly available on CFI’s websites. You are solely responsible for the information and content that you choose to share with other CFI Users and in your Global Corporate Finance Society member profile. CFI has no control over, or responsibility or liability for, the way in which the information or content that you share is collected, used, retained or disclosed by other CFI Users. CFI encourages you to be careful when you share information or content, including the information in your Global Corporate Finance Society member profile.
8. Location and Transfer of Personal Information
CFI and its service providers may process, store and use your personal information at facilities in various location, including Canada, the United States of America, the European Economic Area and Asia.
If you are located in the European Economic Area and we transfer your personal information outside the European Economic Area, we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law. For example, appropriate and suitable safeguards may include the transfer of personal information where the recipient has agreed to a European Commission approved data transfer agreement in the form of the standard contractual clauses under Article 46(2) of the GDPR; or the transfer of personal information to a country that is subject to a European decision of adequacy (e.g. Canada).
If you are located outside the European Economic Area, by providing your personal information to CFI, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.
9. Retention of Personal Information
Please note that all of the above retention periods may be extended where we need to preserve and use personal information for the purposes of bringing or defending a legal claim. In such cases, we will continue to hold and process your personal information for as long as is necessary to deal with the legal proceedings.
10. Your California Privacy Rights
California law permits California residents who provide us with personal information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, at this time, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details. If any other state enacts a law similar to the California law, then this provision will also apply to residents of such states.
11. Do Not Track Signals; Tracking Across Third Party Websites
Certain mechanisms may allow you to send web browser signals known as “Do Not Track” (“DNT”) signals, indicating your choice to disable tracking on our website. We do not respond to browser do not track signals at this time. We may not be aware of or able to honor and respond to every such mechanism. More information about “do not track” is available at www.allaboutdnt.org.
Third parties, other than our vendors (such as our website analytics provider), do not have authorization from us to track which websites you visited prior to and after visiting our website. That said, we cannot control third party tracking and there may be some third party tracking that occurs without our knowledge or consent.
12. Protection of Personal Information
13. Accuracy and Access to Personal Information
CFI will rely on you to ensure that the personal information that you provide to CFI is as accurate, complete and up to date as necessary for the purposes for which CFI uses the personal information. You will promptly notify CFI of any changes to the personal information that you provide to CFI using the procedures made available for that purpose by CFI or by contacting CFI’s Privacy Officer using the contact information noted below.
|Right||Summary of your rights|
|Right of access to your personal information||You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.|
|Right to rectify your personal information||You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.|
|Right to erasure of your personal information:||You have the right to ask that your personal information be deleted in certain circumstances. For example (i) where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation.|
|Right to restrict the use of your personal information||You have the right to suspend our use of your personal information in certain circumstances. For example (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection.|
|Right to data portability||You have the right to obtain personal information that you have provided to us in a structured, commonly used and machine-readable format and for it to be transferred to you or another organisation, where it is technically feasible. The right only applies where the use of the personal information you provided was with your consent or for the performance of a contract with you, and when the use of your personal information is carried out by automated (i.e. electronic) means.|
|Right to object to the use of your personal information||You have the right to object to the use of your personal information in certain circumstances. For example (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes.|
|Right to withdraw consent||You have the right to withdraw your consent at any time where we rely on consent to use your personal information.|
|Right to complain to the relevant data protection authority||You have the right to complain to the relevant data protection authority where you think we have not used your personal information in accordance with data protection law.|
14. Non-Personal Information
15. Other Websites and Businesses
16. Social Networking and Similar Situations
17. Other Matters