Privacy Policy

Your privacy is important to Palette. This Privacy Policy explains how Palette collects, uses, discloses, and retains your information.

 

Your Consent

When you provide Palette with your personal information, you consent to Palette’s collection, use, disclosure, and retention of your information in accordance with this Privacy Policy and Personal Information Protection and Electronic Documents Act (PIPEDA).

 

Personal Information

Personal information is information about an identifiable individual. 

  • How Palette collects your personal information

Prospective Palette students and their legal guardians may be asked to voluntarily provide personal information to Palette anytime they are in contact with Palette, including contact by telephone or email, through this website, or in person. In those circumstances you can choose not to provide certain requested personal information, but then you may not be able to purchase products or services or access or use certain features of Palette’s website.
 
For example, when you register or subscribe to Palette newsletters or participate in Palette’s promotions, and when you contact Palette, Palette may collect a variety of your personal information, including your name, date of birth, mailing address, email address, and phone numbers. 

You might also provide Palette with the personal information of other persons, such as friends and family. Please ensure that you have the consent of other persons before you provide their personal information to Palette. 

  • How Palette uses your personal information

Palette uses your personal information for various purposes, and as otherwise permitted by law, including: (a) to contact and correspond with you regarding your appointments, transactions and your use of Palette’s website, products and services, to provide you with customer care services, and to provide you with information regarding Palette’s announcements, promotions, upcoming events, new products and services (b) to facilitate transactions and process orders and payments for products and services purchased by you (including to remind you of un-purchased items left in your online shopping cart, to contact you regarding billing and payment discrepancies and to validate receipts); (c) to process and respond to your specific suggestions, comments, inquiries, and requests, and to otherwise administer Palette’s relationship with you; (d) to personalize and improve your user experience; (e) to administer and facilitate your participation in contests and promotions; and (f) to develop, deliver, and improve Palette’s products, services, and advertising. 

Palette may combine your personal information collected through various sources, including information collected through Palette’s websites and information obtained from other sources such as the online public domain. 

You may also provide personal information in order to receive email and other communications from Palette. You may unsubscribe from those communications by using the applicable self-service unsubscribe procedure offered by Palette (for example, by clicking an unsubscribe link in an email or adjusting your website user account preferences) or by contacting Palette using the contact information noted below. From time to time, Palette may use your personal information to communicate with you regarding important matters, such as information about your educational program changes, deadlines, program registration changes; because this information is important, you may not opt out of receiving these communications.

Palette may use personal information to create non-personal information, and Palette may then use, disclose, transfer, and retain the non-personal information in accordance with this Privacy Policy.

 

Non-Personal Information

Palette also collects non-personal information - information that is not about an identifiable individual, including personal information that has been aggregated or otherwise anonymized so that it no longer relates to an identifiable individual. For example, Palette’s websites automatically collect certain non-personal information regarding website users, such as the dates and times they access the website, the browsers, operating systems, and devices they use to access the website, the website pages they access, and the referring and exit website pages. 

Palette may use, disclose, transfer, and retain non-personal information for any purpose and in any manner whatsoever. 

If non-personal information is combined with personal information, then the non-personal information will be treated as personal information for the purposes of this Privacy Policy.

 

Cookies and Other Technologies

Palette’s website, online services, email messages, and advertisements may use “cookies” and other similar technologies, such as web beacons, pixel or gif tags, and action tags. Those technologies collect information that assists Palette to improve products and services, advertising, customer communications, and user experience. Palette treats information collected by cookies and similar technologies as non-personal information, provided that if internet protocol (IP) addresses or other similar identifiers are considered personal information under your local laws then Palette will treat that information as personal information for the purposes of this Privacy Policy. 

For example, Palette may use information collected through cookies and similar technologies to recognize the user of Palette’s website, track use of the website, offer personalized web page content, information and advertisements, and otherwise facilitate and improve the website experience. 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 Palette’s website.

Palette may use web beacons, pixel or gif tags, and action tags to confirm that email messages have been delivered and opened. You may opt-out of receiving emails in accordance with this Privacy Policy.

 

Location-Based Services

Palette may provide location-based services, including marketing and promotions specific to your location. To do so, Palette collects (directly or from other service providers) and uses information regarding the geographic location of your devices. If the location data contains your personal information, then Palette will treat the location data as personal information in accordance with this Privacy Policy. If the location data is collected anonymously in a form that does not personally identify you, then Palette will treat the location data as non-personal information in accordance with this Privacy Policy, provided that if the location data is considered personal information under your local laws then Palette will treat that data as personal information for the purposes of this Privacy Policy. 

 

Social Networking and Similar Situations

When you use certain aspects of Palette’s website or other services, or post information to a Palette forum, chatroom, or other social networking service (such as Palette’s Facebook or LinkedIn page) the personal information that you post or share is visible to other persons and can be read, collected, used, and disclosed by other persons, including to send unsolicited messages. You are solely responsible for the personal information that you choose to post or share in those situations. Palette has no control over, or responsibility or liability for, the use, disclosure, and retention of the personal information that you disclose in those situations, and the use, disclosure, and retention disclosure of the disclosed information is not subject to this Privacy Policy. Please be careful when disclosing your personal information in those situations. 

 

Disclosure of Personal Information 

  • To Palette Service Providers

Palette may disclose your personal information to Palette service providers (independently contracted consultants at Palette) to provide products and services to you (including to conduct customer research and satisfaction surveys, and to provide customer communications, data processing and data management, marketing, address validation), to assist Palette to use your personal information in accordance with this Privacy Policy (including to process your transactions and payments, fulfill your orders, deliver products to you, and provide customer service), and as otherwise permitted by law.

For example, Palette engages service providers to help operate Palette’s websites, advertising, and email services and to analyze information collected through websites, advertising, and email (including through cookies and other similar technologies).

Palette requires its service providers to agree to use your personal information only for the purposes for which it is provided to them, and to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy. 

  • To Meet Legal Obligations 

Palette may disclose your personal information as required by legal disclosure obligations under applicable law, including to comply with a subpoena, warrant or court or arbitral order, or litigation disclosure obligations. Palette may also disclose your personal information if Palette reasonably believes disclosure is necessary or appropriate in connection with national security, law enforcement, or other issues of public importance. Palette may also disclose your personal information as otherwise required or authorized by law, or if Palette reasonably believes the disclosure is necessary or appropriate to protect and enforce Palette’s legal rights, interests, and remedies or protect the business, operations, or customers of Palette or other persons (including detecting and preventing fraud). Palette has no control over, or responsibility or liability for, the use, disclosure, and retention of your personal information disclosed in those circumstances, and use, disclosure, and retention of the disclosed information is not subject to this Privacy Policy.

For example, Palette may disclose information to law enforcement authorities or other businesses and organizations in connection with the detection, prevention, and prosecution of activities that Palette reasonably believes to be unlawful or fraudulent, and the disclosed information may include personal information of the individuals suspected of involvement in unlawful or fraudulent activities.

  • Other

Palette may disclose your personal information in connection with a proposed or actual business transaction, such as a corporate reorganization, merger or acquisition, or the sale of some or all of Palette’s business or assets, but Palette will require that the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

 

Retention, Location and Protection of Personal Information

Palette retains your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy or such longer retention period as outlined by PIPEDA. 

Palette will store and process your personal information on cloud-based services provided by Google (e.g. Google Docs, Google Sheets) and other service providers. 

Palette employs reasonable safeguards – including administrative, technical, and physical measures – appropriate to the sensitivity of the personal information in its possession or under its control in order to protect that information from unauthorized access, collection, use, disclosure, disposal, or similar risks.

 

Accuracy and Access to Personal Information

You can help Palette maintain the accuracy and completeness of your information by notifying Palette of any changes to your personal information. 

You may also request access to your personal information and information about Palette’s collection, use, disclosure, and retention of that information by sending your request to Palette’s general email below. This is subject to applicable exceptions and limitations prescribed by law. You will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate.

 

Other Matters

Business Contact Information – To the extent permitted by law, the provisions of this Privacy Policy concerning personal information do not apply to information (such as your name, position or title, business address, business telephone number, business fax number, and business email address) that enable you to be contacted at a place of business.

Personal Information of Children – Palette does not knowingly collect personal information from or relating to children who are under 13 years of age without the consent of the child’s parent or legal guardian. Palette expects parents to supervise and monitor their children’s disclosure of personal information, including through Palette’s website. Please immediately contact us at the general email noted below if you believe that Palette has unintentionally collected personal information from a child under 13 years of age without the consent of the child’s parent or legal guardian. If Palette learns that it has inadvertently collected the personal information of a child under 13 years of age without appropriate consent, Palette will use reasonable efforts to delete that information from its systems and other locations where personal information is stored (except to the extent that retention of the personal information is required or permitted by applicable law).

Employment – Palette may use and disclose your personal information to administer and process your application for employment with Palette and related matters.

Other Websites/Online Services – Palette’s website and online functions may contain links to other websites or online services. When you use those links you are contacting another website or service. Palette has no responsibility or liability for, or control over, those other websites or service or their collection, use, disclosure, and retention of your personal information. Please refer to the privacy policies and terms of use that apply to those other websites or online services.

 

Disclaimer

Policy Changes – Palette may update our Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes. Note that changes to this Privacy Policy are effective when they are posted on this page. Your continued interaction with Palette through various means of contact will be subject to any changes to this Privacy Policy. This will also signify your consent to the collection, use, disclosure, and retention of your personal information in accordance with the changed Privacy Policy. You should check the “Last updated” date of this Privacy Policy (at the bottom of the page) and review any changes since the last version.

 

Last updated:  July 7, 2017