PRIVACY POLICY

A. SCOPE AND APPLICATION OF THE STREAMABLE LEARNING, Inc. PRIVACY POLICY (the "Privacy Policy"):
The Privacy Policy applies to Personal Information about Individuals who interact with the Company’s site or any of its affiliate sites, including www.streamablelearning.com, www.livelearningcanada.ca, and www.streamableu.com. and the Company’s collection, use or disclosure of Personal Information.

The Privacy Policy applies to the management of Personal Information in any form whether oral, electronic or written. The Company reserves the right to amend this Privacy Policy from time to time.

The application of the Privacy Policy is subject to the requirements or provisions of any applicable legislation, regulations or agreements (such as collective agreements), or the order of any court or other lawful authority.

Exclusions from privacy protection:
The Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by the Company: a) aggregate information that cannot be associated with a specific Individual, such as demographic statistics about the Company’s customers, or number of visitors and average time spent on a website; b) information related to program attendance or recorded program viewing that is provided to content partners but which excludes the name of any specific individual and solely includes 1) the name of the school provided by the teacher or legal guardian upon account registration or program registration, 2) the name of the school district provided by the teacher or legal guardian upon account registration or program registration, and the number of students attending provided upon program registration or c) information that is otherwise determined not to be Personal Information pursuant to, or is not regulated by, applicable privacy legislation. This Privacy Policy does not apply to personal information about our employees.

Note to Children
Although parts of the Company’s website provides information and activities for or relating to students, we do not knowingly accept any Personal Information from or about children without parental or legal guardian consent. Teachers, parents or legal guardians must provide their own information (Personal Information or otherwise), or parents or legal guardians must consent to the collection, use and disclosure of their child's Personal Information in accordance with the terms of this Privacy Policy, in order for students to participate in our services or products. The Company encourages parents and teachers to spend time with children and to monitor their online activities. Please protect your child's privacy by instructing them to never provide Personal Information on this website or any other, or within any software registration process, without your permission.

Purposes for Collection and Use of Personal Information:
The Company collects and uses Personal Information for the following purposes: a) to provide the educational programs, products, materials and services requested; b) to establish and maintain responsible commercial relations with Individuals and to provide ongoing services; c) for those purposes set forth in agreements between Individuals and the Company; d) to understand Individuals' needs; e) to develop, enhance, market or provide products and services; f) to manage and develop its business and operations, including personnel and employment matters; and g) to meet legal or regulatory requirements, including to protect or defend a legal interest. When we communicate with Individuals, we will often communicate via electronic means, such as by email.
As examples of the above:
i) The Company may from time to time use an Individual's Personal Information to contact the Individual about changes, enhancements or similar notices related to the Company’s products and services;

Purposes for Disclosure of Personal Information and Transfer of Information:
The Company discloses Personal Information for the following purposes: a) to provide the educational programs, products, materials and services requested (including facilitating logging into to another third party educational programs that are accessed through the Company or a third party provider; b) to establish and maintain responsible commercial relations with Individuals and to provide ongoing services; c) to fulfill the terms of agreements between Individuals and the Company; d) to understand Individuals' needs; e) to develop, enhance, market or provide products and services which we reasonably believe may be of interest to you; f) to manage and develop its business and operations, including personnel and employment matters; and g) to meet legal or regulatory requirements, including to protect or defend a legal interest.
The Company may offer educational programs and services in conjunction with a third-party educational content partner or a video technology partner. For example, the Company’s live streaming program are accessed using an application provided by Zoom, Inc. In that instance, your use of the Company’s service requires you to read and agree to the terms and conditions required by Zoom, Inc. in order to utilize their application. The Company may disclose and share Personal Information with such third-party educational content partners that is reasonably necessary to provide the educational programs and services requested.
From time to time, we may be required to provide Personal Information in response to a court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may release certain Personal Information when we believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves.
You also understand that the Company may use your Personal Information and disclose your Personal Information to Third Parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing the proposed transaction, and you consent to such disclosure. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing Personal Information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use and disclose your Personal Information for substantially the same purposes as described in this Privacy Policy. In the event that the transaction does not go through, we will require by contract the other parties to not use or disclose your Personal Information in any manner whatsoever and for any purpose and to return or destroy same.
The Company may disclose Personal Information to third parties pursuant to and in accordance with the terms of agreements between Individuals and the Company. To the extent there are terms in agreements governing the handling of Personal Information, such terms apply in addition to the terms set out herein.
The Company sometimes transfers Personal Information to others, including to affiliated entities or unrelated companies ("service providers"), that carry out certain functions on our behalf, such as order fulfillment, data processing, accounting and administrative services, customer service and information technology services including, without limitation, hosting and data storage services. In those cases, we require those service providers not to use or disclose Individuals' Personal Information for any purpose other than as directed by the Company. Some of the Company’s educational partners and service providers may be located outside of the United States. As such, Personal Information that is shared or otherwise disclosed to such third parties may be collected, used, processed or stored outside of Canada for the purposes described in this Privacy Policy. The Company takes reasonable contractual or other measures to protect Individuals' Personal Information while processed or handled by these service providers. If an Individual's Personal Information is located outside of Canada it will be subject to legal requirements in those foreign countries applicable to the Company’s service providers, for example, lawful requirements to disclose Personal Information to government authorities in those countries.

Obtaining Consent:
If we require new or additional Personal Information, or if we wish to use your Personal Information in a manner different than as expressed herein or in another agreement with the Individual, the Company will inform Individuals how their Personal Information will be used by the Company. and the Company will obtain consent from Individuals before or when it collects or uses the Personal Information. The Company will not attempt to deceive Individuals into giving consent. An Individual's consent can be express, implied, or given through an authorized representative. An Individual can withdraw consent at any time, with certain exceptions noted herein. The Company may collect, use or disclose Personal Information without the Individual's knowledge or consent in circumstances where such collection, use or disclosure is permitted or as required by law.
Note: If any Individual at any time has any questions or concerns about our Privacy Policy or privacy practices contained herein, the Individual can either:
i) send an email or letter to dashton@streamablelearning.com or Doug Ashton, 38 Romney Street, Charleston, SC 29403, repsecrively.
ii) Call 917-797-0300

Refusing or Withdrawing Consent:
Subject to legal and contractual requirements, an Individual can refuse to consent to the Company’s collection, use or disclosure of Personal Information about the Individual, or an Individual may withdraw the Individual's consent to the Company’s further collection, use or disclosure of Personal Information at any time in the future by giving the Company reasonable notice, unless: i) the consent is otherwise required by law or ii) the use or disclosure is permitted by law or is related to the legal or regulatory requirements described herein. If an Individual refuses to consent or withdraws his or her consent where such consent relates to the provision of requested products or services, the Company may not be able to provide the Individual, or continue to provide the Individual, with such products, services or information.

Internet Aspects:
Information may be collected when an Individual visits all websites of the Company.. Although the information collected, used or disclosed on the Internet as described below often does not constitute Personal Information (and to the extent that such is the case, then the obligations under the Privacy Policy do not extend to such information), The Company provides the details below about Internet aspects of the Company’s services for the purposes of disclosure about the Company’s services.

Internet Protocol Address (IP Address)
When an Individual's web browser requests a web page from another computer on the Internet, it automatically gives that computer the address where it should send the information. This address is called the computer's "IP address." For most users accessing the Internet from a dial-up Internet service provider (ISP), the IP address will be different every time the user logs on. The Company may use the user's IP Address to facilitate the diagnosis and remedy of a technical problem reported by the user's or the Company’s technical team;

The Company uses analytics technology to obtain information to improve the usefulness of the Site. We measure and analyze non-identifying, aggregate usage, and volume statistical information from Site visitors in order to administer the Site, and to constantly improve the quality of our service and site performance. Information gathered may include, but is not limited to, the following: the activity of the Site visitor's browser when the visitor is viewing the Site; the site path of visitors; general information regarding the visitor's internet service provider and host, and the time visitors come to the Site. Please note that this is not personal information, only general summaries of our visitors' usage of the Site.

Links To Other Sites And Advertisements
The Company’s service may contain links to other websites and services. While the Company tries to link only to sites and services that share the Company’s high standards and respect for privacy, a user should understand that the Company is not responsible for the content of, or the privacy practices employed by, other companies or websites. This Privacy Policy applies only to the Company’s services related to this Privacy Policy.

Links from Third Party Portals and Sites
In some instances, in order to access the Company’s education programs and services, you may need to go through third party portals, such as Clever, Safari, or Nelson Education, In those instances, the collection, use and disclosure of your information will also be subject to the terms of such third party’s privacy policy. We ask that you review those and confirm you accept those terms prior to proceeding. In some instances, the third party whose portal is used to access the Company’s education programs and services may share certain Personal Information with the Company. In such instances, the Personal Information provided to the Company shall be subject to the terms of this Privacy Policy.

Additional Information
The Company automatically collects certain information about the user's computer hardware and software. This information may include: browser type, operating system type, domain names, access times and referring Web site addresses. This information is used by the Company to operate the service, to maintain the quality of the service, and to provide general statistics regarding use of the Company’s Sites.

Changes to Privacy Policy
Last updated July 2019. If the Company makes a material change to this Privacy Policy, we will post a notice of same on our website and highlight the changes. We may also notify Individuals via email. Material changes to this Privacy Policy will be binding thirty (30) days after such changes have been introduced and for which notification of such material changes has been made. You may determine when this Privacy Policy was last updated by referring to the date found at the bottom of this Privacy Policy. If at any point you do not agree with the terms of this Privacy Policy, you must not use the Company’s services.

B. The Privacy Policy - Definitions and Principles
Definitions
The Company - means Streamable Learning, Inc. and all its educational sites include Streamable Learning, Live Learning Canada, and StreamableU and any successor company or companies thereof, as a result of corporate reorganization or restructuring.
collection - the act of gathering, acquiring, recording or obtaining Personal Information from any source, including Third Parties, by any means.
consent - voluntary agreement by an informed Individual with respect to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the Individual or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of the Company. Implied consent is consent that can reasonably be inferred from an Individual's action or inaction.
disclosure - making Personal Information available to a Third Party.
Individual - an individual who: a) corresponds with the Company, including complaints and including applications for employment; and b) uses, or applies to use, the products or services of the Company. Personal Information - information that can identify an Individual directly or indirectly or through other reasonably available means, provided that Personal Information shall not include: a) business-contact information, such as the name, title or business address or telephone number of an employee of an organization (when such information is used for business purposes); b) information collected, used or disclosed in the course of journalistic, literary or artistic activities; c) aggregate information that cannot be associated with a specific person, such as demographic statistics about the Company’s customers, or number of visitors and average time spent on a website; or d) information that is determined not to be Personal Information pursuant to applicable privacy legislation.
Third Party - a person other than an Individual or his agent, or an organization other than the Company
use - the treatment, handling, and management of Personal Information by the Company

Privacy Principles Described
Principle 1 - Accountability
The Company is responsible for Personal Information under its control and shall designate one or more persons who are accountable for the Company’s compliance with the following principles.
1.1 Responsibility for ensuring compliance with the provisions of the Privacy Policy rests with the senior management of the Company, which shall designate one or more persons to be accountable for compliance with the Privacy Policy. Other people within the Company may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information.
1.2 The Company is responsible for Personal Information in its possession or control, including information that has been transferred to a Third Party for processing. The Company shall use appropriate means to provide a comparable level of protection while information is being processed by a Third Party (see Principle 7).
1.3 The Company has implemented policies and procedures to give effect to the Privacy Policy, including: a) implementing procedures to protect Personal Information and to oversee the Company’s compliance with the Privacy Policy; b) establishing procedures to receive and respond to inquiries or complaints; c) training and communicating to staff about the Company’s policies and practices; and d) developing public information to explain the Company’s policies and practices.

Principle 2 - Identifying Purposes for Collection of Personal Information
The Company has collected and collects Personal Information for the purposes set out in this Privacy Policy. If such purposes are not contemplated in this Privacy Policy, the Company shall identify the purposes for which Personal Information is collected at or before the time the information is collected.
2.2 Upon request, persons collecting Personal Information shall explain these identified purposes or refer the Individual to a designated person within the Company who shall explain the purposes. 2.3 Unless permitted or required by law, the Company shall not use or disclose, for any new purpose, Personal Information that has been collected without first identifying the new purpose and obtaining the consent of the Individual.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an Individual are required for the collection, use or disclosure of Personal Information, except where inappropriate.
3.1 Providing any Personal Information to the Company signifies consent to the Company’s handling of Personal Information in accordance with the terms of this Privacy Policy. For information handling practices that are not contemplated in this Privacy Policy, The Company shall seek consent to use and disclose Personal Information prior to or at the same time it collects the information. However, the Company may seek consent to use and disclose Personal Information after it has been collected but before it is used or disclosed for a new purpose.
3.2 In obtaining consent, the Company shall use reasonable efforts to ensure that an Individual is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the Individual.
3.3 Where Personal Information is required for the supply of a product or service requested or agreed to by the Individual, the Company will not be able to supply the product or service unless the Individual has consented to the collection, use or disclosure of Personal Information for such identified purpose. 3.4 In determining the appropriate form of consent, the Company shall take into account the sensitivity of the Personal Information and the reasonable expectations of the Individuals.
3.5 In general, the use of products and services by an Individual constitutes implied consent for the Company to collect, use and disclose Personal Information for all identified purposes, so long as the Individual has been made aware of the terms of this Privacy Policy or the applicable identified purpose.
3.6 An Individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. An Individual may contact the Company for more information regarding the implications of withdrawing consent.
3.7 In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Individual. For example, the Company may collect or use Personal Information without knowledge or consent if it is clearly in the interests of the Individual and consent cannot be obtained in a timely way. The Company may also collect, use or disclose Personal Information without knowledge or consent if seeking the consent of the Individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.
The Company may also use or disclose Personal Information without knowledge or consent in the case of an emergency where the life, health or security of an individual or property is threatened.
The Company may disclose Personal Information without knowledge or consent to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise related to the legal or regulatory requirements described herein.
The Company may disclose Personal Information without the consent of the Individuals in other instances which are permitted or required by law.

Principle 4 - Limiting Collection of Personal Information
The Company shall limit the collection of Personal Information to that which is necessary for the purposes identified by the Company. The Company shall collect Personal Information by fair and lawful means.
4.1 The Company collects Personal Information primarily from Individuals through their role as teachers in schools and districts and that information is provided by such individuals in that capacity.

Principle 5 - Limiting Use and Disclosure of Personal Information
The Company may use and disclose Personal Information for purposes consistent with those set forth in this Privacy Policy. The Company shall not use or disclose Personal Information for purposes other than in a manner consistent with the terms of this Privacy Policy, except with the consent of the Individual or as required or permitted by law.
5.1 In addition to uses and disclosure otherwise set out in this Privacy Policy, the Company may disclose an Individual's Personal Information to: a) another person for the development, enhancement, marketing or provision of any of the products or services of the Company; b) to fulfill terms of agreements between the Individual and the Company.; c) a person who, in the reasonable judgment of the Company is seeking the information as an agent of the Individual; d) to permit the provision of services requested by the Individual, and e) a Third Party or Third Parties, where the Individual consents to such disclosure or disclosure is required or permitted by law.
The Company may disclose Personal Information to Third Parties pursuant to and in accordance with the terms of agreements between the Individual and the Company. To the extent there are terms in agreements governing the handling of Personal Information, such terms apply in addition to the terms set forth herein.
You also understand that the Company may use and disclose your personal information to Third Parties connected with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing Personal Information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use and disclose your Personal Information for substantially the same purposes as described in this Privacy Policy.
5.2 Only those employees of the Company who require access for business reasons, or whose duties reasonably so require, or properly designated representatives of the Company are granted access to Personal Information about Individuals.
5.3 Depending on the circumstances, where Personal Information has been used to make a decision about an Individual, the Company shall retain, for a period of time that is reasonably sufficient to allow for access by the Individual, either the actual information or the rationale for making the decision.
5.4 The Company shall make all reasonable effort to delete or destroy Personal Information that is no longer reasonably necessary; however, Personal Information that has been stored and backed-up electronically or is unreasonably inseparable from other information may not be fully deleted.

Principle 6 - Accuracy of Personal Information
The Company shall make reasonable efforts to ensure that Personal Information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
6.1 The Company shall make reasonable efforts to ensure that Personal Information used by the Company is sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an Individual.
6.2 The Company shall update Personal Information about Individuals as and when reasonably necessary to fulfill the identified purposes or upon notification by the Individual.

Principle 7 - Security Safeguards
The Company shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.
7.1 The Company shall protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through reasonable security measures.
7.2 The Company shall protect Personal Information disclosed to Third Parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
7.3 All employees of the Company with access to Personal Information shall be required as a condition of employment to respect the confidentiality of Personal Information.

Principle 8 - Openness Concerning Policies and Practices
The Company shall make readily available to Individuals specific information about its policies and practices relating to the management of Personal Information.
8.1 The Company shall make information about its policies and practices easy to understand, including: a) the title and address of the person or persons accountable for the compliance with the Privacy Policy and to whom inquiries or complaints can be forwarded; b) the means of gaining access to Personal Information held by the Company ; and c) a description of the type of Personal Information held by the Company including a general account of its use.
8.2 The Company shall make available information to help Individuals exercise choices regarding the use of their Personal Information.

Principle 9 - Access to Personal Information
The Company shall inform an Individual of the existence, use and disclosure of his or her Personal Information upon request and shall give the Individual access to that information.
An Individual shall be able to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.
9.1 Upon request, the Company shall afford to an Individual a reasonable opportunity to review the Personal Information in the Individual's file. Personal Information shall be provided in understandable form within a reasonable time and at minimal or no cost to the Individual.
9.2 In certain situations, the Company may not be able to provide access to all of the Personal Information that they hold about an Individual. For example, the Company may not provide access to information if doing so would likely reveal Personal Information about a Third Party or could reasonably be expected to threaten the life or security of another person. Also, the Company may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege/attorney-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to Personal Information cannot be provided, the Company shall provide the reasons for denying access upon request.
9.3 Upon request, the Company shall provide an account of the use and disclosure of Personal Information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, the Company shall provide a list of organizations to which it may have disclosed Personal Information about the Individual when it is not possible to provide an actual list. 9.4 In order to safeguard Personal Information, an Individual may be required to provide sufficient identification information to permit the Company to account for the existence, use and disclosure of Personal Information and to authorize access to the Individual's file. Any such information shall be used only for this purpose.
9.5 The Company shall promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the Individual's file. Where appropriate, the Company shall transmit to Third Parties having access to the Personal Information in question any amended information or the existence of any unresolved differences.
9.6 An Individual can obtain information or seek access to his or her Personal Information by contacting a designated representative at the Company principal office.

Principle 10 - Challenging Compliance
An Individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the compliance of the Company with the Privacy Policy.
10.1 The Company shall maintain procedures for addressing and responding to all inquiries or complaints from Individuals about the Company’s handling of their Personal Information. If any Individual at any time has any questions or concerns about The Company’s Privacy Policy or privacy practices as herein contained, the Individual can either:
i) write to Doug Ashton, 38 Romney Street, Charleston, SC 29403 or by email at dashton@streamablelearning.com
ii) provide information to the Company through the form on its Internet Privacy page.
10.2 The Company shall inform Individuals about the existence of these procedures as well as the availability of complaint procedures.
10.3 The person or persons accountable for compliance with the Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.
10.4 The Company shall investigate all complaints concerning compliance with the Privacy Policy. If a complaint is found to be justified, the Company shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. An individual shall be informed of the outcome of the investigation regarding his or her complaint.

Privacy Inquiry
Please send us your privacy inquiry using the form below. All fields marked with * are mandatory except for e-mail.
*Name
*Address
*Telephone
E-Mail
*Preferred method of contact. If phone, please indicate the best time to call.
*Nature of Inquiry

Last updated July 15, 2019