Privacy Policy for Elite Skills Canada Inc.
Effective Date: April 27, 2025
1. Introduction
1.1 Our Commitment to Your Privacy
Elite Skills Canada Inc. ("Elite Skills Canada," "we," "us," "our") is fundamentally committed to safeguarding privacy and ensuring the confidentiality of the personal information entrusted to us by our users ("you," "your"). This Privacy Policy serves as a comprehensive declaration of our practices regarding the collection, use, disclosure, storage, security, and disposal of your personal information. Our commitment aligns with the core principles of Canadian privacy legislation, aiming to balance your right to privacy with our need to process information for legitimate operational purposes. Establishing and maintaining user trust is paramount, particularly for an organization handling information pertinent to education, career development, and potentially immigration pathways. This policy reflects our dedication to accountability in managing personal information under our control.1.2 Scope of this Policy
This Privacy Policy governs personal information collected through the operation of our website, located at eliteskillscanada.com (the "Site"), and extends to all personal information processed in connection with the delivery and administration of our services. These services include, but are not limited to, the Elite English Program, the Elite Skills Program, and the Ultra Elite Bundle (collectively referred to as the "Services"). Explicitly defining the scope, including the specific services offered, ensures clarity for users regarding the interactions and data processing activities covered under these terms.1.3 Acceptance of Policy
By accessing the Site or utilizing any of our Services, you signify your understanding and acceptance of the terms articulated within this Privacy Policy. Should you disagree with any provision outlined herein, you are advised to refrain from using the Site and Services. Continued use of the Site or Services subsequent to the posting of any amendments to this Privacy Policy will constitute your acceptance of those changes. This mechanism establishes a legal basis for agreement through user interaction, a standard practice for online terms.1.4 Governing Laws
The interpretation and application of this Privacy Policy are governed by the applicable laws of Canada, principally the Personal Information Protection and Electronic Documents Act (PIPEDA), and supplemented by the relevant laws of the Province of Alberta, including the Personal Information Protection Act (PIPA). As Elite Skills Canada operates online, potentially serving users across Canada while possibly having specific ties or targeting within Alberta, adherence to both federal and provincial legislation is necessary for comprehensive compliance. Explicitly stating these governing laws provides legal certainty and demonstrates our commitment to regulatory compliance.
2. Personal Information We Collect
2.1 Information You Provide Directly
We collect personal information that you knowingly and voluntarily provide when engaging with our Site and Services. This includes actions such as registering for an account, purchasing or enrolling in Services, submitting inquiries through contact forms, communicating via email, providing feedback, participating in surveys, or engaging in support interactions. This category represents data actively submitted by the user.2.2 Types of Information Provided Directly
The personal information you provide directly may encompass several categories:
Account Information: This typically includes your full name, email address, phone number, mailing address, chosen password, and potentially other demographic or contact details necessary for establishing and managing your user account.
Payment Information: When purchasing Services, you will provide billing information, including a billing address and payment details (e.g., credit card number, expiry date, CVV). It is important to note that payment processing is typically managed by secure third-party payment gateways. Elite Skills Canada generally receives confirmation of payment and limited transaction identifiers, but does not directly store or process full credit card numbers unless specifically required and disclosed.
Service Usage Information: Data related to your engagement with our Services is collected, such as progress through courses (e.g., Elite English modules), participation records in live sessions, assessment outcomes, and interaction data within the learning platforms.
Elite Skills Program Information: Participation in the Elite Skills Program involves providing information during expert consultations, skills assessments, career mapping exercises, resume and cover letter reviews, and interview coaching sessions. Given the nature of this program, which aims to support career success in Canada, potentially including immigration-related guidance, the information collected may be sensitive. This can include details about your employment history, educational background, specific skills, career objectives, and potentially information related to your immigration status or plans. The collection of such sensitive data necessitates careful handling, robust security, and clear, explicit consent from you.
Communications: We collect the content of your communications with us, which includes messages sent through support channels, feedback submissions, responses to surveys, and any content posted in community forums or discussion areas, if applicable.
2.3 Information Collected Automatically
As you navigate and interact with our Site and Services, certain information may be collected automatically using various technologies. This passive collection relates to your device and how you use our platform.2.4 Types of Information Collected Automatically
Automatically collected information may include:
Log and Usage Data: This encompasses technical details such as your Internet Protocol (IP) address, the type and version of your web browser, your operating system, unique device identifiers, the specific pages you visit on our Site, the time and date of your visit, the duration spent on those pages, the links you click, the referring website address, and other diagnostic data related to your interaction.
Cookies and Tracking Technologies: We utilize cookies (small data files stored on your device), web beacons (also known as pixel tags), and similar tracking technologies to collect information about your browsing activities and preferences. Detailed information regarding our use of these technologies and your choices can be found in Section 10 (Cookies and Tracking Technologies) of this Policy.
2.5 Information from Third Parties
In certain circumstances, we may receive personal information about you from third-party sources. This could include partners like EnGen, particularly if they facilitate your access to our Services or if data sharing is part of an integrated service offering you utilize. We may also receive information from payment processors, such as confirmation of successful transactions. We ensure that such collection from third parties is conducted in compliance with applicable laws, typically requiring your prior consent or relying on the information being publicly available.
Summary of Personal Information Collection
The following table provides a structured overview of the personal information we collect, aligning with the principles of Openness and Identifying Purposes under PIPEDA and PIPA. This format enhances transparency, helping you understand our data practices and make informed decisions regarding your consent.
Category of Information
Specific Examples
Collection Point
Primary Purpose(s) of Collection (See Section 3)
Legal Basis (PIPEDA/PIPA)
Account Information
Name, Email, Phone, Address, Password
Registration Form, Account Profile Updates
Provide & Manage Services, Communicate With You, Security
Consent (Implied/Express), Necessary for Contract Performance
Payment Information
Billing Address, Payment Card Info (via Processor)
Checkout/Payment Page
Process Payments
Consent (Express via action), Necessary for Contract Performance
Service Usage Data
Course Progress, Lesson Participation, Assessment Results, Platform Interactions
Use of Elite English/Elite Skills Programs
Provide & Manage Services, Personalize Experience, Improve Services
Consent (Implied/Express), Necessary for Contract Performance, Legitimate Interest (for aggregated/anonymized improvement)
Elite Skills Program Data
Career History, Skills, Education, Immigration Info (potentially), Aspirations
Consultations, Assessments, Document Submissions (Resume/Cover Letter)
Provide & Manage Services (Elite Skills Program specific)
Explicit Consent (due to sensitivity), Necessary for Contract Performance
Communications Data
Support Tickets, Emails, Feedback, Survey Responses, Forum Posts (if applicable)
Contact Forms, Email Correspondence, Support System, Surveys, Forums
Communicate With You, Improve Services, Provide Support
Consent (Implied via communication initiation), Legitimate Interest (for service improvement)
Technical Data
IP Address, Browser Type, OS, Device ID, Log Data
Website/Service Access
Improve Services, Security & Fraud Prevention, Analytics
Legitimate Interest (Site operation/security), Consent (for non-essential tracking/analytics via Cookies - see Sec 10)
Cookie & Tracking Data
Browsing Activity, Preferences, Ad Interactions (if applicable)
Website Interaction, Cookie Banner Consent
Personalize Experience, Improve Services, Analytics, Marketing (with consent)
Consent (Express/Implied/Opt-out depending on cookie type - see Sec 10), Legitimate Interest (for essential cookies)
Third-Party Data
Name, Email, Usage (from EnGen), Transaction Confirmation (from Payment Processor)
Referrals, Integrated Services, Payment Processing
Provide & Manage Services, Process Payments
Consent (obtained by third party or directly), Necessary for Contract Performance
3. How We Use Your Personal Information (Purposes)
3.1 Principle of Purpose Limitation
Elite Skills Canada adheres strictly to the principle of purpose limitation, a cornerstone of both PIPEDA and PIPA. We collect and utilize your personal information exclusively for purposes that are clearly identified to you before or at the time of collection, for purposes to which you have provided consent, or as otherwise explicitly permitted or mandated by law. Furthermore, all collection, use, and disclosure activities are subject to an overarching standard of reasonableness; we will only process your information in ways that a reasonable person would deem appropriate under the given circumstances.3.2 Specific Purposes
Your personal information is processed for the following specific and legitimate business purposes:
To Provide and Manage Services: This is the primary use of your information. It includes creating, maintaining, and securing your user account; delivering the educational content and features of the Elite English, Elite Skills, and Ultra Elite Bundle programs; tracking your learning progress and performance; providing necessary course materials and resources; facilitating personalized consultations and coaching sessions within the Elite Skills Program; and ultimately, fulfilling the contractual commitments we have made to you upon your enrollment.
To Process Payments: To facilitate the secure processing of payments for subscriptions or one-time service fees through our designated third-party payment processors.
To Communicate With You: To effectively respond to your inquiries submitted via contact forms or email; to send essential service-related notifications, such as policy updates, security alerts, system maintenance announcements, or administrative messages; to provide ongoing customer support; and to solicit feedback through surveys or direct requests to help us understand your experience.
To Personalize User Experience: To enhance your interaction with our Services by tailoring content, learning pathways (such as personalized modules within the Elite English program), and service recommendations based on your past usage patterns, stated preferences, and learning goals.
To Improve Our Services: To analyze aggregated usage data and trends to understand how our Site and Services are being used; to monitor the effectiveness and reach of our programs; to identify and troubleshoot technical issues; to inform research and development efforts for new features, content, or service offerings; and to generate anonymized statistical information for internal planning and reporting. The use of service usage data (e.g., course progress) for both direct service delivery and broader service improvement/analytics is common practice. However, it is important to be transparent about this dual use. While using data to provide the core service relies on implied consent or contractual necessity, employing the same data for analytics beyond basic operational monitoring might be considered a secondary purpose. We strive to use aggregated or anonymized data for such improvement purposes whenever feasible to minimize reliance on identifiable personal information for these secondary analyses.
To Meet Legal and Regulatory Obligations: To ensure compliance with all applicable Canadian and Albertan laws, regulations, legal processes (such as court orders or subpoenas), or enforceable governmental requests; and to establish, exercise, or defend our legal rights in potential disputes.
For Marketing and Promotions (With Consent): Where we have obtained your explicit prior consent (typically through an opt-in checkbox or similar mechanism), we may send you promotional communications, newsletters, information about special offers, or details about new or existing services that we believe align with your interests. You can withdraw this consent at any time. This separation ensures compliance with anti-spam legislation (CASL) and PIPEDA's consent requirements for non-essential communications.
For Security and Fraud Prevention: To maintain the security, integrity, and stability of our Site, Services, and user data; to detect and prevent fraudulent activities or unauthorized access; and to enforce our Terms of Service and other policies.
This detailed enumeration of purposes fulfills legal requirements for transparency and allows users to understand precisely how their information will be handled, forming the basis for meaningful consent.
4. Consent
4.1 Obtaining Your Consent
Elite Skills Canada is committed to obtaining your valid consent prior to collecting, using, or disclosing your personal information, except in specific circumstances where privacy laws permit or require processing without consent (e.g., legal investigations, emergencies). The method used to obtain consent (implied or express) will be appropriate to the circumstances and, critically, the sensitivity of the personal information involved.4.2 Types of Consent
We utilize different forms of consent depending on the context:
Implied Consent: In situations where the purpose for collecting personal information is clearly evident from your actions and the information is not considered sensitive, your consent may be implied. Examples include providing your email address and name to register for an account or continuing to browse our Site after being presented with information about our data practices (e.g., through a cookie banner). We rely on implied consent primarily for the collection and use of non-sensitive information necessary for basic service functionality or website operation.
Express Consent: For any collection, use, or disclosure of sensitive personal information, such as the detailed career, skills, or potentially immigration-related data gathered during the Elite Skills Program, we will obtain your explicit, express consent. Express consent will also be sought for secondary uses of your information that are not essential for service delivery, most notably for sending marketing or promotional communications. Express consent requires a clear, affirmative action from you, such as ticking a dedicated checkbox, clicking an "I Agree" or "Opt-In" button, or signing an agreement. The distinction is vital because sensitive data requires a higher standard of consent affirmation.
4.3 Meaningful Consent
Our goal is to ensure that your consent is always meaningful and informed. In line with guidance from Canadian privacy authorities, we strive to provide clear, accessible, and understandable information before or at the point of collecting your personal information. This includes specifying what data is being collected, the exact purposes for its collection and use, identifying any third parties with whom the information might be shared (including potential transfers outside Canada), and outlining any reasonably foreseeable risks associated with the collection, use, or disclosure.4.4 Withdrawing Consent
You have the right to withdraw your consent to our collection, use, or disclosure of your personal information at any time. To initiate a withdrawal, please contact our Privacy Officer using the details provided in Section 11. Please note that withdrawing consent is subject to legal or contractual restrictions (e.g., we may need to retain certain information for legal compliance or to fulfill ongoing contractual obligations) and requires reasonable notice to implement. We will inform you of any potential consequences of withdrawing your consent, which may include an inability to continue providing certain Services or features that rely on the processing of that information.
Effectively managing these different types of consent across various data points and services necessitates robust internal systems and processes. While this policy outlines the rules (e.g., explicit consent for sensitive data, opt-in for marketing), the practical implementation through user interfaces (like clearly labelled checkboxes, distinct consent requests for the Elite Skills Program, and accessible withdrawal mechanisms) must accurately capture, track, and respect your choices. Failure to manage consent properly in practice, such as using sensitive data based only on implied consent or ignoring a withdrawal request, would constitute a violation of both this policy and applicable privacy laws.
5. Disclosure of Personal Information
5.1 General Principles
Elite Skills Canada does not disclose your personal information to external third parties except under the circumstances explicitly described within this Privacy Policy, when we have obtained your specific consent for disclosure, or when such disclosure is permitted or required by applicable law. Any disclosure made will be strictly limited to the purposes that were identified and for which consent was obtained or which are legally permissible.5.2 Third-Party Service Providers
We engage third-party companies and individuals ("Service Providers") to perform various functions necessary for the operation of our business and the delivery of our Services. These functions may include website hosting, data storage and processing, performance analytics, payment processing, customer relationship management (CRM), email delivery services, marketing support, and technical assistance. We may share your personal information with these Service Providers, but only to the extent necessary for them to perform their designated functions. Crucially, under PIPEDA's accountability principle, we remain responsible for the personal information transferred to these providers. We ensure through contractual agreements that these Service Providers are obligated to maintain the confidentiality and security of your information, use it solely for the purposes we have authorized, and implement safeguards providing a level of protection comparable to our own. This requires diligent selection of providers and robust contractual terms covering data protection, security standards, use limitations, breach notification, and potentially audit rights.5.3 Payment Processors
To process payments for our Services, we utilize established third-party payment processors (Stripe). When you initiate a payment, your financial details (like credit card number, expiry date, security code) are typically provided directly to the chosen payment processor through their secure interface. The processor's handling of your personal information is governed by their own privacy policy, which we strongly encourage you to review. Elite Skills Canada generally does not store your full payment card details; we typically receive only confirmation of the transaction's success, transaction IDs, and possibly partial card information for verification purposes.5.4 EnGen (for Elite English Program Users)
Enrollment in the Elite English Program necessitates the sharing of certain personal information with EnGen, the third-party provider of the language upskilling platform utilized for this program. Information shared may include your name, email address, and data related to your usage of the platform and progress within the courses. This disclosure is essential for enabling your access to the EnGen platform, tracking your learning activities, providing personalized content, and facilitating necessary support. EnGen may process this data acting either as our service provider under contract or potentially as an independent controller, subject to their own terms of service and privacy policy. We strongly advise you to review EnGen's Privacy Policy, accessible at: https://getengen.com/privacy-policy, to fully understand how they collect, use, store (including processing in the United States), and protect your information, as well as how you can exercise your privacy rights directly with them.5.5 Legal and Regulatory Authorities
We may be compelled to disclose your personal information if required by law, such as in response to a subpoena, court order, search warrant, or other legally valid request from law enforcement or government authorities. Disclosure may also occur if we believe in good faith that it is necessary to: comply with a legal obligation; protect or defend the rights, property, or safety of Elite Skills Canada, our users, or the public; prevent or investigate potential fraud or wrongdoing related to our Services; or protect against legal liability. Any such disclosure will be strictly limited to what is legally required or permitted.5.6 Business Transactions
In the event that Elite Skills Canada undergoes a significant business transaction, such as a merger, acquisition by another company, sale of assets, financing round, reorganization, or bankruptcy proceeding, your personal information may be transferred as part of the assets involved in that transaction. Should such a transfer occur, we will endeavor to provide you with notice before your personal information is transferred and becomes subject to a different privacy policy, where feasible and legally permissible. Alberta's PIPA contains specific provisions governing the disclosure of personal information during business transactions, and we will adhere to these requirements.5.7 No Sale Without Consent
Elite Skills Canada explicitly states that we will not sell, rent, lease, or otherwise trade your personal information with third parties for their own marketing or commercial purposes without first obtaining your express, affirmative consent.
6. Data Security and Storage
6.1 Our Security Commitment
Elite Skills Canada is deeply committed to protecting the security and integrity of your personal information. We implement and maintain a range of reasonable administrative, technical, and physical security measures. These safeguards are designed to protect the personal information under our control from risks such as unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction. The level of security employed is appropriate to the sensitivity of the information being protected, recognizing that data related to the Elite Skills Program may require enhanced measures.6.2 Security Measures
Our security practices include, but are not limited to, the following measures:
Utilizing encryption technologies, such as Transport Layer Security (TLS/SSL), to protect data transmitted over the internet between your browser and our servers.
Implementing strict access control protocols, ensuring that internal access to personal information is restricted to authorized personnel whose job responsibilities require such access (a "need-to-know" basis).
Employing secure server infrastructure and partnering with hosting providers who maintain high security standards (e.g., potentially adhering to certifications like ISO 27001 where applicable for cloud services).
Conducting regular reviews and assessments of our information collection, storage, processing, and security practices to identify potential vulnerabilities and enhance protection against unauthorized access. This ongoing process is crucial as the concept of "reasonable" security evolves with technological advancements and changing threat landscapes.
Mandating through contractual agreements that third-party service providers who handle personal information on our behalf implement and maintain comparable security standards.
Providing appropriate training to our employees regarding privacy principles, security procedures, and their responsibilities in handling personal information securely.
6.3 Security Disclaimer
While Elite Skills Canada diligently employs commercially reasonable security measures to protect your personal information, it is important to acknowledge that no method of transmitting data over the Internet or storing data electronically can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the absolute security of any information you transmit to us or store on our systems. Users also share responsibility for data security by maintaining the confidentiality of their account passwords and login credentials.6.4 Data Storage Location(s)
Personal information collected by Elite Skills Canada is primarily stored and processed on secure servers located within Canada. However, to provide our Services effectively, we may utilize third-party service providers (such as EnGen for the Elite English Program, payment processors, or cloud hosting and analytics providers) whose operations may be based in other countries, notably the United States. Therefore, your personal information may be transferred to, stored in, and processed in jurisdictions outside of Canada. Section 8 (Cross-Border Data Transfers) provides further details on these transfers.
7. Data Retention
7.1 Retention Principle
Elite Skills Canada retains personal information only for the duration necessary to fulfill the specific purposes for which it was originally collected. This includes retention necessary to provide ongoing Services, satisfy legal, regulatory, tax, accounting, or reporting obligations, or to resolve potential disputes. This practice aligns with Principle 5 of PIPEDA and corresponding PIPA requirements.7.2 Determining Retention Periods
The specific retention period for different types of personal information is determined based on several factors, including: the volume, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure if retained longer than necessary; the purposes for which the information was processed and whether those purposes can be achieved through other means; and applicable legal or regulatory retention mandates. In accordance with PIPEDA and PIPA, personal information that has been used to make a decision directly affecting an individual (e.g., assessment results influencing program progression) will be retained for a sufficient period (as prescribed by law or for a reasonable time) to allow the individual meaningful access to that information following the decision. While this policy outlines the principles, effective compliance relies on established internal guidelines that specify minimum and maximum retention periods for various data categories (e.g., account data, course progress, consultation notes, financial records) to prevent indefinite or unnecessary retention, which increases risk and contravenes privacy laws.7.3 Secure Disposal
Once personal information is no longer required for its identified purposes and any mandatory legal retention periods have expired, Elite Skills Canada will take appropriate steps to securely dispose of it. This involves destroying, erasing, or anonymizing the information in a manner designed to prevent unauthorized parties from gaining access. Methods may include secure shredding of physical documents, using data overwriting techniques for electronic media, degaussing magnetic media, or complete physical destruction of storage devices where appropriate.
8. Cross-Border Data Transfers
8.1 Potential for Transfers
As indicated in Section 6.4, the operation of our Site and the provision of our Services may involve the transfer of your personal information across international borders. This occurs when we utilize third-party service providers located outside of Canada, such as cloud hosting platforms, analytics services, payment processors, or specialized service partners like EnGen (whose platform is hosted in the United States). Consequently, your personal information may be transferred to, stored in, and processed in jurisdictions including, but not limited to, the United States.8.2 Accountability and Safeguards
Elite Skills Canada remains accountable for the protection of your personal information even when it is transferred to a third party in another jurisdiction for processing. In accordance with PIPEDA Principle 4.1.3, we employ contractual agreements and other appropriate means to ensure that any third party processing your information abroad provides a level of protection that is comparable to the protection the information would receive if it remained in Canada. These contractual safeguards typically include clauses addressing data confidentiality, purpose limitations, security requirements, breach notification protocols, and limitations on further disclosure. While PIPEDA's approach relies on organizational accountability and contractual measures rather than formal "adequacy decisions" like the EU's GDPR, the legal landscape governing international data transfers is complex and subject to change. We commit to monitoring relevant legal developments in Canada and key jurisdictions like the U.S. to ensure our transfer mechanisms continue to provide adequate protection.8.3 Notice Regarding Foreign Access
It is important for you to be aware that when your personal information is located outside of Canada, it becomes subject to the laws of the jurisdiction(s) where it is stored or processed. These laws may differ from Canadian privacy laws and could potentially permit courts, law enforcement agencies, regulatory bodies, or national security authorities of that foreign jurisdiction to access your personal information under certain circumstances. This notice is provided in accordance with guidance from the Office of the Privacy Commissioner of Canada and requirements under Alberta's PIPA.
9. Your Privacy Rights
9.1 Your Rights Under PIPEDA and PIPA
Canadian federal (PIPEDA) and Alberta provincial (PIPA) privacy legislation grant individuals specific rights concerning their personal information held by organizations. Elite Skills Canada is committed to upholding these rights, which are outlined below. Please note that these rights may be subject to certain legal limitations and exceptions as defined within the governing statutes.9.2 Right to Access
You have the right to request access to the personal information that Elite Skills Canada holds about you. Upon receiving a verifiable written request, we will inform you of the existence, use, and disclosure of your personal information and provide you with access to that information. We will respond within the legally mandated timeframes (typically 30 days under PIPEDA, 45 days under PIPA, potentially extendable under specific circumstances). A minimal fee may be charged for processing access requests where permitted by law (though PIPA prohibits fees for accessing personal employee information). Access may be lawfully denied under specific circumstances, such as if granting access would likely reveal personal information about another individual without their consent, disclose confidential commercial information, compromise an investigation, or involve information protected by legal privilege. If access is denied, we will provide written reasons for the refusal.9.3 Right to Correction (Rectification)
You have the right to challenge the accuracy and completeness of your personal information held by us and request that it be amended or corrected if it is inaccurate or incomplete. We will make the necessary corrections where appropriate. If we do not agree with the requested correction (e.g., if we believe the information is accurate), we will not change the information but will place a note on the file indicating the correction that was requested but not made.9.4 Right to Deletion (Erasure/Withdrawal of Consent Leading to Deletion)
You have the right to withdraw your consent to our processing of your personal information, as detailed in Section 4.4. PIPEDA's Principle 5 requires that personal information no longer necessary for its identified purposes must be destroyed, erased, or made anonymous. Therefore, withdrawing consent or the fulfillment of the purpose for which data was collected will typically lead to the deletion or anonymization of the relevant personal information, unless legal or contractual obligations require us to retain it. While Canadian law does not provide a broad, unqualified "right to be forgotten" equivalent to the GDPR, you can request the deletion of your information if it was collected unlawfully, is no longer needed for the purposes for which it was collected, or if you have withdrawn consent upon which its processing was based. However, practical limitations may exist; for example, data may persist in backup archives until overwritten according to schedule, or certain records (like transaction history) may need to be retained for legal or audit purposes. We will honor deletion requests to the fullest extent possible within these legal and operational constraints, ensuring deleted data is removed from active systems and not used further.9.5 How to Exercise Your Rights
To exercise your right to access, correct, or request deletion of your personal information, or to withdraw consent, please submit your request in writing to our designated Privacy Officer. Contact details are provided in Section 11. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections. We are committed to responding to your requests promptly and in accordance with the requirements of PIPEDA and PIPA.
10. Cookies and Tracking Technologies
10.1 Use of Cookies
Elite Skills Canada's Site utilizes cookies and may employ similar tracking technologies, such as web beacons or pixels. These technologies are used for various purposes, including enabling essential website functionality, enhancing your browsing experience, analyzing website traffic and usage patterns, personalizing content based on your preferences, and, where applicable and with your consent, delivering targeted advertising. Transparency regarding cookie usage is a key requirement under Canadian privacy guidance.10.2 What are Cookies?
Cookies are small text files containing a string of characters that are placed on your computer or mobile device when you visit a website. They allow the website to recognize your device and remember certain information about your visit, such as preferences or login status.10.3 Types of Cookies We Use and Purposes
The types of cookies potentially used on our Site can be categorized as follows:
Essential/Strictly Necessary Cookies: These cookies are indispensable for the proper functioning of the Site and the provision of Services you request, such as enabling secure login, maintaining your session, or processing transactions. Consent is generally not required for these cookies, as the Site cannot function correctly without them.
Performance/Analytics Cookies: These cookies collect information about how visitors use our Site, such as which pages are visited most often, how users navigate between pages, and if they encounter error messages. This data, often aggregated and anonymized, helps us understand user behavior and improve the Site's performance and usability. We may use third-party analytics tools like Google Analytics for this purpose.
Functionality Cookies: These cookies allow the Site to remember choices you make (like your username, language preference, or region) and provide enhanced, more personalized features.
Targeting/Advertising Cookies: These cookies may be set by us or by third-party advertising partners to track your browsing habits across websites. They are used to build a profile of your interests and show you advertisements that are more relevant to you on other sites. The use of these cookies requires your explicit consent.
10.4 Third-Party Cookies
Some cookies present on our Site may originate from third-party service providers, such as analytics platforms (e.g., Google Analytics) or advertising networks. These third parties collect and use data according to their own privacy policies. We do not have direct control over these third-party cookies, but we select providers who respect privacy principles.10.5 Managing Your Preferences / Consent
We respect your right to control the use of cookies. Upon your initial visit to our Site, and potentially at regular intervals, you will likely encounter a cookie consent banner or management tool. This tool will provide clear information about the types of cookies used and their purposes, and will allow you to provide or withhold consent for non-essential cookies (Performance/Analytics, Functionality, Targeting/Advertising). Canadian privacy guidance suggests that while express (opt-in) consent is generally required for tracking and targeting cookies due to their potential privacy impact, implied consent (with clear notice and an easy opt-out) might be permissible for less intrusive analytics cookies. Our consent mechanism aims to provide granular choices and respect user preferences, including potentially recognizing browser-based "Do Not Track" signals where feasible. You can also typically manage or delete cookies through your web browser's settings. However, please be aware that disabling essential cookies may impair the functionality of the Site and Services.
11. Privacy Officer and Contact Information
11.1 Designated Privacy Officer
Elite Skills Canada has designated a Privacy Officer who holds the responsibility for overseeing our compliance with this Privacy Policy and all applicable Canadian and Albertan privacy laws. This appointment fulfills the accountability requirements mandated by PIPEDA and PIPA.11.2 Contact Information
Should you have any questions, concerns, or complaints regarding this Privacy Policy, our data handling practices, or if you wish to exercise any of your privacy rights (as detailed in Section 9), please direct your inquiries in writing to our Privacy Officer:
Privacy Officer, Elite Skills Canada Inc, info@eliteskillscanada.com
Providing clear and accessible contact information is essential for the principles of Openness and Challenging Compliance.
11.3 Addressing Concerns
Elite Skills Canada is committed to addressing all privacy inquiries and complaints promptly and thoroughly. We will investigate concerns raised and respond in accordance with applicable legal requirements. If, after contacting us, you remain unsatisfied with our response or handling of your concern, you have the right to escalate the matter by lodging a formal complaint with the appropriate privacy regulatory authority: the Office of the Privacy Commissioner of Canada (for PIPEDA matters) or the Office of the Information and Privacy Commissioner of Alberta (for PIPA matters).
12. Changes to This Privacy Policy
12.1 Policy Updates
This Privacy Policy may be amended or updated periodically to reflect changes in our operational practices, service offerings, technological advancements, or evolving legal and regulatory requirements. The "Effective Date" displayed at the beginning of this document indicates the date of the most recent revision. We encourage users to review this Policy regularly to stay informed about how we protect personal information.12.2 Notification of Changes
If we implement changes to this Privacy Policy that are considered material (i.e., significantly altering how we collect, use, or disclose your personal information, or affecting your rights), we will provide notice before the changes take effect. This notification may be delivered via email to the address associated with your account, through a prominent notice posted on our Site, or by other means required or permitted by law. This practice ensures ongoing transparency and allows you to review changes before they become effective.
13. Effective Date
This Privacy Policy is effective as of April 27, 2025.