Canopy Certified Inc.Privacy Policy
Last modified:  October 30, 2020

Introduction
Canopy Certified Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.This policy describes the types of information we may collect from you or that you may provide (i) when you visit our Website, www.canopyky.org (our “Website”); (ii) when we provide services to you, your company or your employer; (iii) when your company or your employer goes through our certification process; (iv) when you contact us; and (v) when you work for us as an employee or contractor.  This policy also describes our practices for collecting, using, maintaining, protecting, transferring, disclosing and deleting that information.We collect information in connection with providing services.  The services that we provide may be provided directly to you or may be provided to your company or your employer.  The services that we provide include assessments, certifications and consulting for companies which you own or which may be your employer.  The services may involve training, coaching and workshops.This policy applies to information we collect:

  •       On this Website and other Canopy associated websites (including Canopy Certification Portal).
  •       In email, text and other electronic messages (i.e. Slack) between you and our Website, including during the certification process or participation in a survey or review.
  •       Through mobile and desktop applications you download from our Website, which provide dedicated non-browser-based interaction between you and our Website.
  •       In connection with providing services to you or your company or employer.
  •       When you visit our offices or a location where we are providing a training session, a presentation or services or have a physical presence and are collecting information provided to us.
  •       When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
  •       In connection with surveys or studies conducted to gather market information and insights for publication or otherwise for our program.

It does not apply to information collected by a third party, including through any application or content (including advertising) that may link to or be accessible from our Website.Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, your choice is not to use our Website or our services.  By accessing or using this Website or our services, you agree to this Privacy Policy.  This policy may change from time to time (see “Changes to Our Privacy Policy”).  Your continued use of this Website or our services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.Children Under the Age of 18Our Website is not intended for children under 18 years of age.  No one under age 18 may provide any information to or through the Website.  We do not knowingly collect personal information from children under 18.  If you are under 18, do not use or provide any information on this Website or through any of its features, make any application on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use.  If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under 18, please contact us at certified@canopyky.org.Information We Collect About You and How We Collect ItWe collect several types of information from and about users of our Website, including information:

  •       By which you may be personally identified, such as name, postal address, e-mail address, telephone number, any other identifier by which you may be contacted online or offline, or as well as information which may be on any application and results of assessments in which you participate (collectively, “personal information”);
  •       Information provided about a business during the certification process;
  •       Marketing communications and cookie references;
  •       Detail of your contact with us;
  •       That is about you but individually does not identify you, such as searches you perform and clicks on categories on our Websites; and/or
  •       About your internet connection, the equipment you use to access our Websites, and usage details.

We collect this information:

  •       Directly from you when you provide it to us.
  •       Automatically as you navigate through the site.  Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
  •       From social networks when you use social network logins to access our Website or get information about our services, you will share certain personal information from you social media account with us, for example name, email address, photo, social media contacts and other information that may be, or you make, accessible to us when you connect your social media account to our Website or an account (specific information transfers depends on you security settings and the policy of the social media network);
  •       Publicly available databases; and/or
  •       From third parties, for example, our business partners.

Information You Provide to Us.  The information we collect on or through our Website may include:

  •       Information that you provide by filling in forms on our Website.  This includes information provided at the time of subscribing to any material or service, posting material or requesting further services or information.  We may also ask you for information when you report a problem with our Website.
  •       Records and copies of your correspondence (including email addresses), if you contact us.
  •       Information you provide in connection with the application process or consulting services which may include your name, title, professional and personal contact information, demographic data, information about the business, results of an assessment, survey or questionnaire you or others complete, compensation, objectives, memberships, community involvement, educational background, work history, other qualifications, reputation, responses to interview questions and financial detail.
  •       Your responses to surveys that we might ask you to complete for research purposes.
  •       Your search queries on one of our Websites.
  •       Details of transactions you carry out through our Website and of the fulfillment of your requests.  You may be required to provide financial information before placing an order through our Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”).  Your User Contributions are posted on and transmitted to others at your own risk.  Please be aware that no security measures are perfect or impenetrable.  Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions.  Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.Information We Collect Through Automatic Data Collection Technologies.  As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  •       Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
  •       Information about your computer and internet connection, including your IP address, operating system and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).  See below for information on how you can opt out of behavioral tracking and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.The information we collect automatically may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties.  It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  •       Estimate our audience size and usage patterns.
  •       Store information about your preferences, allowing us to customize our Website according to your individual interests.
  •       Speed up your searches.
  •       Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  •       Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access certain parts of our Website.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  •       Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website.  Flash cookies are not managed by the same browser settings as are used for browser cookies.  For information about managing your privacy and security settings for Flash cookies (see “Choices About How We Use and Disclose Your Information”).
  •       Web Beacons. Pages of the Website and some of our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “do not track” (“DNT”) or similar feature that signals to digital services that a visitor does not want to have online activity tracked.  If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block that digital service from collecting certain personal information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, we and many other digital service operators may not respond to DNT signals.  For more information about DNT signals, visit http://allaboutdnt.com.Information We Receive or Collect When You Access Our Website on Mobile Devices.  If you access our Website on your mobile telephone or other mobile device, including iPads and tablets, we collect your mobile device identifier and IP Address.  We may create and assign to your device an identifier that is similar to an account number.  We may collect the name you have associated with your device, device type, telephone number, country and any other information you choose to provide, such as user name, character name, geo-location or email address.  As you may access our Website with more than one device, we can track data from all devices that you use and aggregate it in your profile and elsewhere in our system.Email Communications.  When you open email from us, we may receive a confirmation notifying us that you opened the email.  We also may keep track of what emails we send you.  Additionally, we keep a record of what communications you have selected to receive or not to receive.  If we send emails other than in direct response to emails you send us and you would like to opt-out of receiving such emails, please click on the “unsubscribe” link in the email and follow the instructions.Social Network Site (SNS) Notifications/Text Message.  If used, we may receive and store the information you provide, including your mobile telephone number, when you opt in to have SNS notifications/text messages sent directly to your mobile phone.  If available, these messages notify you of events or other matters.  You can adjust the types of notifications you receive and when you receive them by editing your SNS notification settings.  If we use these and you no longer wish to receive SNS text messages from us, please log in to your account and change your settings or click on the “opt out” link contained in an SNS message received by you.Information about You Received from an SNS.  When you access our Website through an SNS, such as Facebook, you allow us to access and import certain information from your profile for that SNS which may affect the privacy settings you establish on the SNS.  You can find out more about the settings on the SNS.  For example, we may access and store some or all of the following information depending on your settings and the SNS:

  •   your first and last name;
  •   your profile picture or its URL;
  •   your user ID number, which is linked to publicly available information such as name and profile photo;
  •   the login email you provided to the SNS when you registered;
  •   your physical location and that of your access device;
  •   your gender;
  •   your birthday; and
  •   where and when you stream or upload a video or other content to a third-party service such as Facebook or YouTube.

By entering our Website through an SNS, you are authorizing us to collect, store and use any information that the SNS provides to us through the SNS interface with our Website.  You agree to this when you “accept” or “allow” (or similar term) one of our applications on the SNS.Information Posted by Visitors.  We may make available through our Website services such as message boards to which you are able to post information, photos, images and other materials.  Please note that, if allowed, any information, photos, images or materials you disclose through such services, through social media or otherwise on our Website become public information, and may be available to visitors to our Website all over the world and to the general public.  This relates to information posted on our Website in forums or similar services and not in connection with the certification application the responses to which are not “posted” on our Website.  In addition, when you choose to make a posting on such services, certain personal data will be available for other users to view.  We urge you to exercise discretion and caution when deciding to disclose personal data, or any other information, on our Website.  WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL DATA YOU VOLUNTARILY DISCLOSE THROUGH OUR WEBSITE.Third-Party Use of Cookies [and Other Tracking TechnologiesOur Website may contain links to third-party websites.  These linked websites are not under our control, and we are not responsible for the privacy practices or the contents of any such linked website or any link contained in any linked website.  We provide such links only as a convenience, and the inclusion of a link on our Website does not imply endorsement of the linked website by the Company.  If you provide any personal data through any such third-party website, your transaction will occur on the third party’s website (not our Website) and the personal data you provide will be collected by and controlled by the privacy notice or policy of that third party.  We recommend that you familiarize yourself with the privacy notice and policies and practices of any third parties.  PLEASE NOTE THAT THIS PRIVACY NOTICE DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers.  These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website.  The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.  They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.We do not control these third parties’ tracking technologies or how they may be used.  If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.  For information about how you can opt out of receiving targeted advertising from many providers, see “Choices About How We Use and Disclose Your Information”.How We Use Your InformationWe use information that we collect about you or that you provide to us, including any personal information:

  •       To present our Website and its contents to you.
  •       To provide you with information, products or services that you request from us, including in connection with the certification process.
  •       To fulfill any other purpose for which you provide it.
  •       To provide you with notices about your certification, including expiration and renewal notices.
  •       To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  •       To notify you about changes to our Website or any products or services we offer or provide though it.
  •       To allow you to participate in interactive features on our Website.
  •       To link to online identifiers or IP addresses assigned to you and to other demographics or interest-based data in order to target you with relevant advertising.
  •       To deliver, customize and target the advertising and content you see.
  •       To send promotional material or special offers on behalf of ourselves, our marketing partners and/or their respective affiliates and subsidiaries and other third parties.
  •       To develop new products and services, and to consider ways of enhancing, improving or modifying our current products or services.
  •       To conduct audits to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
  •       To improve our marketing and promotional efforts, to statistically analyze site usage, and to customize our content, layout and services.
  •       To request additional information from you for various purposes.
  •       To contact you about our Website, technical support, your account or other inquiries.
  •       To monitor and prevent fraud or potentially illegal activities and monitor and enforce our Website’s terms of use.
  •       In any other way we may describe when you provide the information.
  •       For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you.  If you do not want us to use your information in this way, please email us at certified@canopyky.org.  For more information, see “Choices About How We Use and Disclose Your Information”.We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.  Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.We may also use or disclose information to resolve disputes, investigate problems or enforce our terms and conditions relating to a sale, our Terms our services, enforce our Terms of Use, or otherwise.  At times, we may review status or activity of multiple users to do so.  We may disclose or access information whenever we believe in good faith that the law so requires or if we otherwise consider it necessary to do so to maintain service and improve our services.  We use your IP address to help diagnose problems with our server, to manage our Website and to enhance our Website based on the usage pattern we receive.In some cases relating to our collection and processing of your personal information, we may ask for your consent so that we may process your personal information.  However, in other circumstances applicable data protection laws or regulations allow us to process your personal information without needing to obtain your consent.Cases in which separate consent is not required include:

  •       For the performance of a contract, such as fulfilling orders you have made or services you request.
  •       Legitimate interests of the Company, including performing contractual obligations to you and requirements of applicable law, except where such interests are overridden by your interests or fundamental rights and freedoms as a data subject which require protection of personal information.
  •       To communicate with you regarding our Website and services, including to provide you with notices regarding changes and to respond to your requests, questions or complaints.
  •       For our direct marketing purposes.
  •       For third party marketing purposes related to the services we provide.
  •       To send you surveys in connection with our business.
  •       To assist in the investigation of any suspected illegal or wrongful activity and to protect and defend our rights or the rights and safety of third parties.
  •       To develop, provide or improve our Website and services.
  •       To enforce our Terms of Use, this Privacy Notice or agreements with third parties.
  •       To comply with legal obligations.
  •       To protect the vital interests of you or another person.

In circumstances for which we are not relying on our legitimate interests or another basis for processing personal information, under applicable law, we may ask for your consent to process your personal information.  Some of the areas on which consent may be required when we are not relying on our legitimate interest are marketing and use of cookies.Disclosure of Your InformationWe may disclose aggregated information about our users, and information that does not identify any individual, without restriction.We may disclose personal information that we collect or you provide as described in this privacy policy:

  •       To our affiliates.
  •       To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  •       To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  •       To third parties to market their products or services to you if you have not opted out of these disclosures.  For more information, see “Choices About How We Use and Disclose Your Information”.
  •       To fulfill the purpose for which you provide it.
  •       For any other purpose disclosed by us when you provide the information.
  •       With your consent.

We may also disclose your personal information:

  •       To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  •       To enforce or apply our Terms of Use [https://canopyky.org/terms-of-use] and other agreements, including for billing and collection purposes.
  •       If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.  This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your InformationWe strive to provide you with choices regarding the personal information you provide to us.  We have created mechanisms to provide you with the following control over your information:

  •       Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.  If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  •       Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to certified@canopyky.org.
  •       Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to certified@canopyky.org.  If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.  This opt out does not apply to information provided to the Company  relating to the certification process or as a result of a product purchase or other transactions.
  •       Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending an email to certified@canopyky.org.

We do not control third parties’ collection or use of your information to serve interest-based advertising.  However these third parties may provide you with ways to choose not to have your information collected or used in this way.  You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.Accessing and Correcting Your InformationYou may also send us an email at certified@canopyky.org  to request access to, correct or delete any personal information that you have provided to us.  We cannot delete your personal information except by also deleting your user account.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.  Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use [https://canopyky.org/terms-of-use]Data SecurityWe have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.The safety and security of your information also depends on you.  If we have given you (or where you have chosen) a password for access to certain parts of any of our Website, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.  Any transmission of personal information is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures contained on our Website.WE TAKE SECURITY PRECAUTIONS IN AN EFFORT TO PROTECT YOUR INFORMATION AGAINST SECURITY BREACHES.  HOWEVER, THIS IS NOT A GUARANTEE THAT SUCH INFORMATION MAY NOT BE ACCESSED, DISCLOSED, ALTERED OR DESTROYED BY A BREACH OF SECURITY MEASURES RELATING TO ONE OF OUR WEBSITES OR FACILITIES.  YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND AGREE TO ASSUME THESE RISKS.Data RetentionWe back up all information on our system, including your personal information onto servers via secured networks that are collected periodically, currently nightly.  Quarterly backups are archived for three years and then destroyed.  We will retain your information on the current system for as long as we believe your account may be active or as otherwise necessary to provide you services.  We also will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.  In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.  We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.Third Party PracticesThe privacy notice or policy of an advertiser or promotional service appearing at our Website may differ from ours.  We encourage you to read that notice or policy before responding to any offer.Legal NoticesAll material on our Website, including, without limitation, all informational text, the design and all “look and feel” layout, photographs, graphics, audio, video, messages, messaging design and functions, files, documents, images or other materials (collectively, the “materials”), whether publicly posted or privately transmitted, as well as all derivative works, are owned by the Company, its affiliates or other third parties that have licensed to or otherwise permitted their material to be used by us, and are protected by copyright, trademark and other intellectual property laws.  You agree not to display or use such marks without our prior written permission.  We disclaim any proprietary interest in trademarks, service marks, logos, slogans, domain names and trade names other than our own.Except as specifically provided, the materials on our Website may not be copied, reproduced, republished, uploaded, posted, transmitted or distributed in any way, including by email or other electronic means.  Any modification of the materials, use of the materials on any website or networked computer environment, or use of the materials for any purpose other than as allowed by us is a violation of the copyright, trademark and other proprietary rights in the materials and is expressly prohibited.Changes to Our Privacy PolicyIt is our policy to post any changes we make to our privacy policy by reflecting a new date as the last modified date at the beginning of the policy. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page.   You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.Contact InformationTo ask questions or comment about this privacy policy and our privacy practices, contact us at:certified@canopyky.orgor via our phone number: 502-907-3268To register a complaint or concern, please see the information about dispute resolution in our Terms of Use [https://canopyky.org/terms-of-use].