Privacy Policy
Last updated: July 30, 2024
Teamwurk Ltd. O/A Wolf & Willow Solutions ('Wolf & Willow', 'We', 'Us') provides a range of services including: consulting services, and the delivery of training programs, courses and bootcamps in partnership with post-secondary institutions (PSEs). Wolf & Willow is committed to respecting the privacy of its website users and protecting their personal information in accordance with the legislative requirements in the jurisdictions we operate and under the Government of Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). This Web Privacy Statement explains the current practices employed by Wolf & Willow for collecting, using and protecting information collected from its website users.
We created this privacy policy ('Privacy Policy') to outline how we collect, use, and disclose personal information through the Wolf & Willow websites located at https://wolfwillowsolutions.com and all other domains connected to Wolf & Willow Solutions (collectively, the “Website”), or sub-domains we manage on behalf of our PSE partners, in the course of providing partnered educational programming, data management, marketing and related services (collectively, the 'Services').
Your privacy is of great importance to us. By visiting our Website(s), and sub-domains managed by us or using our Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy.
1. WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers our collection, use, and disclosure of information about identifiable individuals and information that is linked to identifiable individuals ('Personal Information'), including those who visit our Websites, apply for our programs, and use our Services ('Users'). This Privacy Policy does not apply to the practices of companies that we do not own or control, including those of service providers we use to process data ('Service Providers'). Service Providers are responsible for maintaining their own privacy policies governing the collection, use, and disclosure of Personal Information.
2. COLLECTION AND USE OF PERSONAL INFORMATION
2.1 Prospective Student Information
When you apply for a course or program, Wolf & Willow collects your name, email, city, phone number, and preferred pronoun. We use this Personal Information to communicate with you regarding the status of your application. Wolf & Willow will collect information about your application, including reason for applying, self-assessed skills and technical proficiencies, education history and work experience, goals, and other personal characteristics. We use this Personal Information to assess your application and determine eligibility for our programs. We may also collect personal financial information in order to assess your eligibility for scholarships and other funding options. In addition, this information may be used to produce aggregate reports and market research that showcase demographic information of our applicants.
Wolf & Willow may also collect name and contact information of prospective students at events, through our Websites, or otherwise to send information about our Services.
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Wolf & Willow will use the contact information provided to notify users of important information relevant to our Services. You may opt out of receiving marketing communications; however, despite your indicated email preferences, we may send you relevant notices where permitted by law.
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We may also ask you to provide information related to your gender and/or status as an indigenous student to determine your eligibility for scholarships and other funding options.
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2.2 Student’s Personal Information
When you register for a program, Wolf & Willow will collect information to process tuition fee payment or to apply for funding/financing, this may happen in one of the following ways:
a) Credit Card or Debit Card Payment: your credit or debit card information to process payments for tuition fees. We use Stripe, a third-party payment processor, to process payments on our behalf.
You will provide debit or credit card information directly to our payment solutions provider that operates a secure server to process payment details, encrypting your credit/debit card information, and authorizing payment. Information that you supply to our payment solutions provider is not stored by us or within our control and is subject to our payment solutions provider's own privacy policy and terms and conditions.
b) Funding or Financing: to be eligible for funding or financing options, you will be required to provide information related to funding or financing eligibility criteria, which may income information about your income, and may include a credit check. Financing options are provided by a third-party financing provider who will collect and process any credit check applications directly on our behalf.
To register in a course or bootcamp, students will be asked to provide address, age, birthday, emergency contact name and phone number, visa information (if applicable), and any third-party funding assistance information.
When you participate in course activities, Wolf & Willow will collect your test/quiz scores, assignment evaluation scores, requests for assistance, and general progress through the curriculum. This information is used to evaluate your performance in the program and this information will be shared with our PSE partners, specifically the partner you are registered with for their own record keeping and credential issuance purposes.
Wolf & Willow employs other companies, partners, and suppliers (such as contract instructors and career services providers) to perform tasks on our behalf, and we may need to share your information with them to provide products and services to you, in which case we do so under conditions of confidentiality and only to the extent necessary for the purpose at hand.
2.3 Graduated Students
Once you have completed a course delivered by Wolf & Willow on behalf of the PSE institution you are registered with, we will request information related to your job status, resume, and job salaries. We may supplement this information with publicly available information. This information is used by Wolf & Willow to assess the employment prospects of graduates and assist in finding job opportunities. Additionally this information supports our ongoing efforts to ensure our programming is of top quality, and aligned with our goal of producing job ready graduates.
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2.4 Cookies
Technologies such as cookies, beacons, scripts, and tags are used by us and our third-party partners, namely Google Analytics. These technologies are used to analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and provide relevant advertising. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers and third-party service providers may offer their own management tools for removing these types of tracking technologies.
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Standing alone, cookies do not identify you personally. They merely recognize your browser. However, Wolf & Willow uses session cookies containing encrypted information to allow the system to uniquely identify you while you are visiting the Website. This information allows Wolf & Willow to process online transactions and requests, including completing applications. Session cookies help us make sure you are who you say you are after you've logged in to our Learning Management System and are required to use the Service.
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Third parties, including Facebook, and LinkedIn may use cookies, web beacons, and other storage technologies to collect or receive Personal Information from the Websites and elsewhere on the internet and use that information to provide measurement services and targeted ads.
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We also use Google Analytics to evaluate our web traffic. Google may collect your IP address to analyze web traffic.
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2.5 Employees and Contractors
Wolf & Willow collects Personal Information from our employees and contractors for the purposes of contacting them, administering payroll, and keeping track of records for tax purposes. In particular, we collect from employees name, email, address, SIN, birthday, and direct deposit banking information. We also keep track of employment information such as salary and job performance. We collect from contractors name, email address, payment rates, tax business numbers, and direct deposit information.
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3. SECURITY AND STORAGE
3.1 Storage Location
Wolf & Willow stores its applicant and student data, including Personal Information, on servers located in Canada. In particular, student records are stored using Data Witness, a secure recording hosting provider. By submitting any Personal Information or using the Services, you agree to this transfer, storing, or processing of your Personal Information in Canada.
In addition, Wolf & Willow uses third-party Service Providers and sub-processors outside of Canada, including in the United States. Wolf & Willow uses the following cloud-hosting services and CRM software services to store some Personal Information, specifically name, address, phone numbers, email address, birthdate, programs of interest and communication preferences. These services include Google, Zoho, Thinkific, Calendly, SurveyMonkey, TypeScript, Heroku, Mailchimp, Quickbooks, Discourse, DataWitness, and AWS Canada.
You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in those countries under lawful access regimes or court order.
3.2 Security
The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or password for the Services.
4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
4.1 Disclosure of Statistical Data
Wolf & Willow may disclose aggregate statistical data to its business partners, who may use the data to better understand the demographics of our users. This information does not include any Personal Information or otherwise identify any individuals.
4.2 Service Providers and Business Partners
We may, from time-to-time, employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third-party companies and individuals employed by us to facilitate our products and services.
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Contract instructors for Wolf & Willow will also have access to Personal Information of their students as necessary to administer the course.
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Additionally, we forward completed student records inclusive of all registration data/information to our PSE partners to support maintenance of their registration records and credential issuance requirements. Our PSE partners maintain their own independent Privacy Policies, which are of the utmost integrity, but are ultimately separate from ours and not within our control. Wolf & Willow does not maintain a record of any credentials issued to you by our PSE partners, and those records can only be accessed through contacting those partners directly.
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4.3 Business Transfers
If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
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4.4 With Your Consent
If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will contact you and will request your express consent as required under applicable privacy laws.
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5. RETENTION
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. Specifically, we are required to store student records to meet regulatory obligations.
We may also retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.
6. ACCESS, CORRECTION, AND ACCURACY
You have the right to access the Personal Information we hold about you to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances, we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete, or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
7. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used, or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website after such changes have been first posted.
8. RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”)
Wolf & Willow generally processes Personal Information to fulfill agreements we have with our students and to pursue our legitimate business interests listed above. Otherwise, we will obtain consent from an individual in respect of the processing of Personal Information.
Further, individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individuals who are located in the EEA and who wish to exercise these rights should contact Wolf & Willow using the contact information below. If the inquiry relates to Personal Information collected by one of our Online Store providers or other third parties, you should contact such third party. Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.
9. ADDITIONAL INFORMATION
You can help by keeping us informed of any updates to your contact information or other Personal Information. If you would like to access your Personal Information, if you have any questions, comments, or suggestions about our Privacy Policy or practice, or if you find any errors in our Personal Information about you, please contact us at: hello@wolfwillowsolutions.com
10. REVIEW AND UPDATES
This policy is scheduled for review and updating annually, 1-month prior to the month of creation, or as needed.
Creation Date: December 14, 2022
Authority: Doug Wotherspoon, Co-Founder and CTO