Lighthouse Labs

PRIVACY POLICY

Lighthouse Labs Inc. Privacy Policy

Lighthouse Labs Inc. (‘Lighthouse Labs’, ‘We’, ‘Us’) is the creator and owner of the Lighthouse Labs accelerated learning programs for coding education. We created this privacy policy (‘Privacy Policy’) in order to set out how we collect, use, and disclose personal information through the Lighthouse Labs websites located at https://lighthouselabs.ca (collectively, the “Website”), in the course of providing our educational programming, coding bootcamps and related services (collectively, the MServices’).

The privacy of our users is of great importance to us. By visiting our Website or 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 Website, 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.

Lighthouse Labs is a private career college and, as a result, Lighthouse Labs is required by law to collect and retain certain Personal Information related to student records for regulatory purposes.

2. COLLECTION AND USE OF PERSONAL INFORMATION

2.1 Prospective Student Information

When you apply for a course or program, Lighthouse Labs 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. Lighthouse Labs 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.

Lighthouse Labs may collect name and contact information of prospective students to provide us with this information at events, through or Website, or otherwise in order to send information about our Services.

Lighthouse Labs will use the contact information provided to notify users of important information that is relevant to the Services. You may opt out of receiving marketing communications; however, despite your indicated e-mail preferences, we may send you relevant notices where permitted by law.

We may also ask you to provide information related to your gender and/or status as an indigenous student for the purpose of determining your eligibility for scholarships and other funding.

2.2 Student Information

When you register for a program, Lighthouse Labs will collect your credit information in order to process payments for tuition fees. We use Stripe, a third-party payment processor, to process payments on our behalf.

To enroll in a course, students will be asked to provide address, age, birthday, emergency contact name and phone number, Canadian visa information (if applicable), and third-party funding assistance information. We are required to collect this Personal Information in order to meet our regulatory obligations.

We also collect your t-shirt size in order to provide you with a Lighthouse Labs shirt.

When you participate in course activities, Lighthouse Labs 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 course.

2.3 Graduated Students

Once you have completed a course at Lighthouse Labs, 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 Lighthouse to assess the employment prospects of our graduates and assist in finding job opportunities.

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 in analyzing trends, administering the Website, tracking users’ movements around the Website, gathering demographic information about our user base as a whole and providing 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.

Standing alone, cookies do not identify you personally. They merely recognize your browser. However, Lighthouse Labs uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged into the Website. This information allows Lighthouse Labs 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 in order to use the Service.

Third parties, including Facebook, 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.

We also use Google Analytics to emulate our web traffic. Google may collect your IP address in order to analyze web traffic.

2.6 Mailing List

If you choose to subscribe to our mailing list, Lighthouse Labs will collect your email address in order to send you updates on our products and services. You can unsubscribe from the mailing list at any time.

2.7 Employees and Contractors

Lighthouse Labs 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.

3. SECURITY AND STORAGE

3.1 Storage Location

Lighthouse Labs stores its student data, including Personal Information, on servers located in Canada. In particular, student records are stored using Data Witness, a secure recording hosting providing. 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, Lighthouse Labs uses third-party Service Providers and sub-processors outside of Canada, including in the United States. Lighthouse Labs uses the following cloud-hosting services and CRM software services to store some Personal Information: Google Drive, Heroku, Mailchimp, Zoho ATS, Quickbooks, Discourse and Digital Ocean.

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

Lighthouse Labs may disclose aggregate statistical data to its business partners, who may use the data for 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.

Contract instructors for Lighthouse Labs will also have access to Personal Information of their students as necessary to administer the course.

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.

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 notify you and/or obtain your express consent as required under applicable privacy laws.

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 in order 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”):

Lighthouse Labs generally processes Personal Information in order 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 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 to the EEA and who wish to exercise these rights, should contact Lighthouse Labs 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@lighthouselabs.ca

Last Updated: October 31, 2018