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Privacy Notice

The Change Playbook Privacy Notice & Your Privacy Rights

Effective as of November 2022

Welcome! The Change Playbook™ is an online platform that provides change management practice information features to help users become more proficient and successful change management practitioner through the TCP website (the “Site“) (collectively, our “Services“). The Change Playbook (“TCP”) provides this Privacy Notice to inform you of our policies and procedures regarding the collection, use and disclosure of your Personal Data and other data when you use our Services. For purposes of the European General Data Protection Regulation No. 679/2016 (“GDPR“) and similar data protection laws, TCP processes your Personal Data as a data controller. This Privacy Notice is not a contract and does not create any legal rights or obligations.

Unless otherwise defined in this Privacy Notice, terms used in this Privacy Notice have the same meanings as in our Terms of Use.

As used in this Privacy Notice, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within our organization or among our affiliates within Canada or internationally.

Summary

Information Collection and Use

We collect (1) Personal Data that you have voluntarily shared with us; (2) data concerning your activity when using the Services; and (3) data that is otherwise collected through other sources. We use your Personal Data to provide you with the Services, operate, maintain, and improve our Services, understand your interests, confirm and fulfill your orders, provide customer service, provide product maintenance and troubleshooting, respond to your requests, provide marketing and other communications, manage security and prevent fraud or criminal activity, enable you to interact with our Services, and for other purposes we may notify you of from time to time.

Legal Basis for Processing

We process your Personal Data to satisfy our contractual obligations to you; based on your consent; to protect the legitimate interests of TCP or other parties; or to comply with legal obligations.

Data Retention

We use your Personal Data for as long as is necessary to achieve the intended purpose.

Information Shared with Others

Your data may be shared (1) with other users; (2) with service providers; (3) with other third-party services; or (4) to comply with the law.

International Transfers

We take measures to protect your data when we transfer it to another country.

Managing Your Data

You can access, integrate, update, amend, and delete your Personal Data.

Security

The security of your data is important to us so we have implemented measures designed to safeguard your Personal Data against loss, theft, and unauthorized use, disclosure, or modification, but please be aware that no transmission of information over the Internet is 100% secure.

Links to Other Sites

We may link to other sites, but we are not responsible for their practices.

Our Policy Toward Children

We do not knowingly collect data from individuals under age 16.

Amendments and Updates

We may update this Privacy Notice from time to time.

CONTACT US

You can contact us by sending us an email at privacy@thechangeplaybook.com, using the information provided in the Contact Us section below or on this website.

1. Information Collection and Use

Our primary goals in collecting information are to provide and improve our Services and to enable our users to enjoy, use, and easily navigate our Services. To provide you with a consistent user experience and to recognize you as a user across our Services, we may collect and combine data as described below; for example, data collected when you visit the Site from one browser or device may be combined or linked with data collected when you visit the Site from a different browser or device, which may also be combined or linked with product usage data.

Generally, we collect two types of information: Personal Data and Other Information. “Personal Data” is information that can be used to identify or is reasonably linkable to you as an individual and may include Usage Information (as defined below). “Other Information” is information that is not linkable to you as an identifiable individual, including information that has been de-identified or aggregated with data from other users.

Personal Data we may collect. When you use the Services, we may collect the following Personal Data:

  • Your contact information, such as your first and last name, email address, mailing address, and phone number;
  • Your billing information, such as your credit card number and billing address;
  • Your TCP account information, including your user name, account number, and your encrypted TCP password;
  • Information you voluntarily provide about yourself;
  • Your user experience preferences, order history, and marketing preferences;
  • Your user content (including video and images) you provide to use certain features, including content you submit, and other information you provide;
  • Your Usage Information, as described further below; and

Your Personal Data is processed only to the extent necessary to pursue the purposes set out in this Privacy Notice. To learn about how long TCP keeps your Personal Data, see Section 3, Data Retention.

Many of our services and features require some Personal Data. If you choose not to provide the necessary Personal Data, you may not be able to use certain services or features. If you choose not to share your Personal Data, features that require personalization will not work for you.

Data From Others. Other parties may provide us with Personal Data. For example, if you create a TCP account using your login from another party’s service (including a social media network), we will access and collect the information about you that your privacy settings on that service permit so that we can create an account for you.

Use of Personal Data. We use your Personal Data to provide our Services and administer your inquiries. For example, when you create an account through the Services and become a Registered User or when you choose to create your own profile, we may ask you for Personal Data so we can create your account or populate your profile (see “Registered Users” below). We may also use your Personal Data to update our Services or features, troubleshoot, protect our Sites and users, or provide support to you.

We also use your Personal Data to improve and develop our products and services, personalize our services, better understand consumers’ interests related to our products and services, make recommendations to you, and send you relevant offers. We may also use your Personal Data to send you TCP newsletters, marketing or promotional materials, or other information that may be of interest to you. We will obtain your consent to send you these communications. If you decide at any time that you no longer wish to receive them, please follow the unsubscribe instructions provided in any of the communications or update your user preferences information.

Registered Users. Once you become a Registered User, you will be able to create a profile page by submitting certain Personal Data. The profile page may be viewable by other TCP users and will display your profile name as well as your profile picture, if you choose to upload one or agree to allow a Third-party service to provide one for you. You can choose what other Personal Data you provide as part of your profile. Providing such information is voluntary and should correlate with the degree of interaction you want to have with TCP and its users.

Other Information. Other Information will be considered Personal Data if it is combined with other data in such a way that enables you to be identified. However, where Other Information is taken alone or combined only with other non-identifying information, it will not be treated as Personal Data. We may use Other Information for any purpose, unless prohibited by law.

We may combine your Personal Data with Other Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how our Services are used. We may also use the combined information without aggregating it to serve you specifically—for instance, to deliver information to you according to your preferences or restrictions.

Usage Information. When you visit or use the Services or use a TCP website, we may automatically record information about your online session (“Usage Information“). This Usage Information may include information such as your computer’s Internet Protocol (IP) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site or the App that you visit (or of the site you visited that had the TCP feature), the time spent on those pages, information you search for, access times and dates, the model and device ID number of your mobile device, user settings, location (if you enable this feature), and statistics and information about your use of the Site and App. We use this information to provide and improve the Services, develop new content, and offer products and services that may be of interest to you. We also use Usage Information to monitor and analyze use of the Services, for technical administration, to secure the Site and App and protect those who visit the Site or App, to improve functionality and user-friendliness, and to better tailor our Services to our visitors’ needs. For example, some of this information is collected so that when you revisit the Services, we will recognize you and can serve advertisements and other information appropriate to your interests. Some of the Usage Information (like your IP address) is treated as Personal Data.

Cookies. Like many websites, we use cookies, pixels, web beacons, APIs and similar technologies to collect Usage Information. Pixels and web beacons are small pieces of code placed on web pages and content that communicate when the page or content has been viewed. A cookie is a small data file that your browser places on your computer that helps us understand how you interact with the Site and use our Services. We use two types of cookies. We use persistent cookies to save information like your search preferences, your account settings and login information, so that we can remember you and your settings when you return to the Site or App, and personalize your experience. We use session cookies to enable certain features of our Services, but unlike persistent cookies, session cookies are deleted when you leave or log off and/or when you close your browser. Third-party advertisers on the Site or in the App may also place or read cookies on your browser. Most Internet browsers automatically accept cookies but you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of or all functionality of our Services.

We may also use other parties (including Google Analytics and Mixpanel) to provide usage analytics for our Services. These other parties will place their own cookies to collect traffic and activity data in order to deliver us relevant metrics and information. The collection of this data by these other parties is subject to their own privacy notices.

2. Legal Basis for Processing

Below is an explanation of the different legal grounds we have for processing your Personal Data:

  • To satisfy our contractual obligations to you. For example: allowing you to register for an account; providing the Services to you; and fulfilling your orders and providing additional services.
  • With your consent. For example: processing your entry into a prize promotion/competition; sending you customized marketing communications related to our products and services electronically (including email and notifications from other party’s services); and sharing your Personal Data with our selected trusted partners to help us send customized marketing communications.
  • When we have a legitimate business interest to do so. For example: managing the requests for information you send us, including handling complaints; preventing fraud; enforcing our rights before the courts; improving the performance and security of our products and our Services, including the Site; sending you customer care communications concerning products or services you have used or which you showed interest in, and in order to carry out customer satisfaction surveys; unless you opt-out, contacting you for marketing purposes by phone (non-automated) and via paper mail; and carrying out activities useful for the transfers of business and business branches, takeovers, mergers, demergers, or other transformations and for the execution of such transactions.
  • For legal obligations. We may also use your Personal Data to the extent necessary to comply with our legal obligations.

If you do not want TCP to use your electronic contact details for marketing purposes, you can always follow the instructions to “unsubscribe” in our emails; or in accordance with Section 12 of this Privacy Notice below.

3. Data Retention

TCP will process your Personal Data for as long as it is necessary to achieve the purposes described above. If you delete your account we have processes designed to delete or de-identify your Personal Data. If you do not use your account or receive emails from us for an extended period of time, we have processes designed to delete or de-identify your Personal Data.

Keep in mind that we will retain information to comply with the law, prevent fraud and protect TCP, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our agreements, and take other actions permitted by law.

4. Information Shared with Others

We only share your Personal Data as described in this Privacy Notice. Through the Services, you are able to share your Personal Data when you share something through our Service, when you give us your consent to do so (like when we notify you that the information you provide will be shared in a particular manner and you provide us with such information), when you share Personal Data with another party’s service (if you allow such sharing), or when you share Personal Data with others with whom you want to connect (according to the preferences you have set in your account).

We may share Other Information, such as de-identified data, with other parties.

Your Personal Data is shared with:

Institute X Inc. TCP is a partially-owned subsidiary of Institute X Inc. Any data, including Personal Data collected by TCP, may also be shared with Institute X Inc.

Other Users. When you post comments or content on any TCP message boards or blogs, or when you use other interactive features made available through or in connection with the Services, any data you choose to include will be accessible to other users. We urge you to be very careful when deciding to make any of your Personal Data, or any Other Information, publicly available through the Services. If you choose to use any social network features and widgets, such as a “share” button or interactive mini-programs that we may offer through the Services, these features may collect your IP address and information about which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by another party or hosted directly on our Website. Your interactions with these features are governed by the privacy statements of the companies and social media networks providing them.

Service Providers. We may share any of your data with companies and individuals we engage to facilitate our Services, to market our services, to provide services to us or on our behalf, to perform related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of our features) or to assist us in analyzing how our Services are used. We may also share information about your use of TCP products with service providers that store this information to improve the Services.

Business and Advertising Partners. With your consent, we may share your Personal Data with other parties to allow them to send you marketing communications about their own products and services. Cookies and tracking technologies may be used on our Services, which allows us and advertising networks, social media companies, and other providers to place or display ads relevant to you on our Services, as well as on other websites, apps, services, and devices you may use. We may share hashed contact information from our marketing database with social media or advertising companies (e.g., LinkedIn, Google, etc.), which—if you have an account with these companies—may be used to serve you ads more likely to be relevant to you and to serve ads to other people that these companies believe are similar to you (sometimes known as “LookAlike Audiences” or “Similar Audiences”). Many social media and advertising platforms allow you to configure your ad settings through your account on their platforms. You may also opt out of such sharing by contacting our Privacy Office and asking to be opted out of marketing.

Compliance with Laws and Law Enforcement. In certain situations, TCP may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. TCP cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of TCP, Institute X, or a third-party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical, or legally actionable activity.

Business Transfers. TCP may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

5. International Transfers

The Services are offered globally so it may be necessary to transfer your information internationally. In particular, your information will be transferred to and processed in Canada where TCP and our servers are located. The data protection and other laws of other countries, such as Canada, may not be as comprehensive as those in your country. The processing activities performed by TCP may be regulated by data protection laws in your own country, in addition to Canadian privacy laws. We rely on legal bases to lawfully transfer Personal Data internationally, including your consent and EU Commission approved model contractual clauses (which require certain privacy and security protections)

6. Managing Your Data

We give you options to help you understand what Personal Data we use and to request that we change how we use it. At any time, you may contact us to:

  • be informed on the purposes and methods of the processing of your Personal Data;
  • ask for access to your Personal Data (commonly known as making a “data subject access request“). This enables you to receive a copy of the Personal Data we hold about you;
  • ask for updating or rectification of the Personal Data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
  • request erasure of your Personal Data. This enables you to ask us to delete or remove your Personal Data where there is no good reason for us continuing to process it. You can also ask us to delete or remove your Personal Data where you have successfully objected to processing or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for reasons which will be communicated to you, if applicable, at the time of your request;
  • restrict the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where you allege that our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
  • object to the processing, wholly or partly, of your Personal Data where we are relying on legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
  • where we are relying on consent to process your Personal Data, you can revoke the consent to the processing of your Personal Data freely and at any time, and also opt-out of marketing communications by clicking on the unsubscribe option at the bottom of our marketing communications; or
  • make your Personal Data available to you or to a different provider in some circumstances. We will provide to you, or a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that Personal Data we process based on our legitimate interests (or those of a third-party) may not be portable.

If you wish to manage your data as described above, or raise any questions about the Personal Data we hold about you, please contact us using the contact information below.

There is generally no charge for you to exercise any of the data management options described in this section, but we may charge a reasonable fee if you make excessive or unfounded requests. In some cases, depending on where you live, you have the right to lodge a complaint in front of the competent national data protection or judicial authority if you object to how we use your Personal Data.

7. Interest-Based Advertising/Your Choices

As described above, we and other parties we do business with (including advertisers on the Site), may place or recognize unique cookies or other technologies on your browser or device when you visit the Site. In addition to the uses above, these technologies enable the collection of information about online activities over time and across different websites and apps, which can be used to customize advertisements to you as you browse the Internet. In accordance with the Digital Advertising Alliance (DAA) Self-Regulatory Principles for Online Behavioral Advertising, you can opt-out of having information regarding your online behavior collected and used for advertising purposes. To learn more about interest-based advertising, or to opt out for your web browser, please visit optout.aboutads.info or optout.networkadvertising.org. Options you select and choices you make are browser, website and device specific. If you clear your cookies or your browser’s cache, you will need to set your preferences again.

Do Not Track. Some web browsers may give you the ability to enable a “do not track” setting; however, our Services do not respond to “do not track” signals at this time.

8. Security

TCP is concerned with safeguarding your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access; however, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact Us section below.

9. Links to Other Sites

Our Services may contain links to other websites, apps, and platforms. If you click on an ad or another third-party link, you will be directed to that third-party’s website, app, or platform. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third-party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Data from you. Other sites follow different rules regarding the use or disclosure of the Personal Data you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any other parties.

10. Our Policy Toward Children

Our Service is not directed to children and we do not knowingly collect personally identifiable information from children under 16. If we become aware that we have collected Personal Data from a child under 16 (or any other age specified by applicable law), we will take steps to delete such information from our files as soon as possible.

11. Amendments and Updates

We may occasionally update this Privacy Notice. Please review the Effective Date at the top of this page to see when this Privacy Notice was last revised. If we make any material changes we will notify you as required by law, which may include by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Your use of the Services following these changes means that you accept the revised Privacy Notice.

12. Contact Us

If you have any questions about this Privacy Notice, please contact us via email at privacy@thechangeplaybook.com, or please write to us at the following address:

The Change Playbook
Institute X Inc.
148 Michael Street
Carleton Place, ON  K7C 0G4

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