NeonTrain Inc. Privacy Policy
May 2022
NeonTrain Inc. provides its clients certain online goods and services including, without limitation, access to the learning management system known as BRIGHTSPACE™. BRIGHTSPACE™ is a cloud-based collection of learning tools that allows individuals to experience interactive online learning. We refer to BRIGHTSPACE™ and our other service offerings as the “Services”.
At NeonTrain, we are committed to protecting the privacy of our users. This Privacy Policy applies to personal information we collect and use through our Services. The Services are hosted by NeonTrain, D2L Corporation (“D2L”) and other third-party service providers. We refer to NeonTrain as we, us and our.
Individuals who access the Services usually do so by virtue of an agreement that we have with an institution (educational or otherwise), employer or other organization with which the user is associated. We refer to the institution, employer or other organization as the “Organization”. Consumer users include visitors to our websites and individuals who access BRIGHTSPACE™ or other Services by virtue of an agreement directly with us.
If you were given access by an Organization, this Privacy Policy does not affect or control that Organization’s collection, use or disclosure of your information. Collection and use of information in this way is governed by the privacy policies of your Organization.
WHAT PERSONAL INFORMATION MAY BE COLLECTED?
“Personal information” means information which identifies you or by which your identity may be deduced. The personal information we collect will depend on which Services you use. It will usually include your name, address, email address, employer, position and work location however, in certain circumstances it may also include application, membership and other related numbers.
By providing any personal information to us or sharing personal information with others (including sensitive information) using BRIGHTSPACE™ or other Services you expressly and voluntarily consent to the storage and processing of that personal information in accordance with the terms and conditions of this Privacy Policy and any applicable user agreement (including an end-user license agreement or service agreement) that allows us to store and process personal information about you. When you provide information, that information may reside on our system, or our service providers’ systems. You understand and agree that personal information collected through our Services may be stored and processed by us, our affiliates or our third party service providers in Canada, the United States and other countries, including countries other than your country of residence. The laws of the jurisdiction in which the information is stored and processed will apply to its storage and processing. Those laws may require the disclosure of personal information to governmental authorities under circumstances that are different than those that apply in Canada.
HOW WE COLLECT INFORMATION
We may collect personal information from you in the following ways:
Registration for Services
In order to access some of the Services, you may be asked to create an account that will require you to provide us with information. Certain Services allow you to provide additional information voluntarily. Providing information beyond what is required at registration is optional, but providing such information may enable you to derive more benefit from the Services.
Information collected as we provide services to your Organization
We may also collect personal information about you if your Organization has contracted with us for professional services or end-user support. This information may include your name, email address or other personal information. Information collected in connection with our provision of professional services to your Organization is collected for the purpose of providing such support efficiently and effectively. Information collected through the use of our support is intended to help resolve issues as quickly as possible, and to ensure that you can be notified of the progress of any issues that you describe.
Cookies and Web Beacons
Like most websites, we use technologies, such as cookies and web beacons, to collect information about the pages you view, the links you click and other actions you take in using our Services.
HOW WE USE YOUR INFORMATION
Unless we compelled to do so by law or if we sell off any part of our business operations, we will never sell your personal information or use it for purposes not described in this policy. We use your personal information to manage your use of any Services. We will also use it to monitor and improve our existing Services, to develop new Services, and to conduct research and develop statistics about our Services. While we may disclose or sell those research and statistics to third parties, any information which can identify individuals will first be completely removed.
These uses include providing you with more effective customer service, making our Services easier to use by eliminating the need for you to enter or repeatedly enter the same information, performing research and analysis aimed at improving our Services and websites, and displaying content and advertising that is customized to your interests and preferences.
Some of our Services are accompanied by interactive features such as chat rooms, forums, messaging and other ways to share. If you submit information it may be used to provide the Service offerings that you requested, and may also be used for activities related to the purpose for which you’ve submitted the information.
SHARING YOUR INFORMATION WITH THIRD PARTIES
We may share your information with third parties who are not our partners or service providers only in the following situations:
As required by law
Sharing with Your Organization
Information will be shared with the Organization through which you accessed the Services.
Information You Share with Other Users
Our Services may enable you to share information with or send communications to other users or the general public. You or your Organization may select the other users with whom you share or to whom you send this information. Once you share information with or send information to other users, however, those other users may share your information at their discretion.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
We offer users the ability to access or correct information collected during registration or during the use of our Services. You may correct this information at any time and as often as necessary by contacting your organization’s approved contact with NeonTrain.
We may decline to provide you with access to, or to change, your personal information if (a) your request is not provided in writing, (b) your request does not provide us with sufficient detail to identify the personal information you seek to access or change, (c) we are unable to verify your identity to our satisfaction, (d) we deem, in our sole discretion, that it would be unreasonable in the circumstances to provide you with access to or to correct your personal information, or (e) legislation permits or requires us to do so.
You should also contact your Organization for questions about access to the personal information collected by your Organization.
RETENTION OF YOUR INFORMATION
We may retain your personal information for so long as you maintain an active account or user profile, or as needed to provide you with the applicable Services.
Please be aware that as long as you have access to BRIGHTSPACE™ or other Services, you cannot opt out of receiving service messages from us. Also, if we send communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with your receipt of messages on your mobile device (including text messaging charges).
INFORMATION SECURITY
It is impossible to eliminate all risk of misuse of, or unauthorized access to, your personal information. There is no such thing as perfect security, and we cannot guarantee or warrant the security of any data (including personal information) that we receive and store on our system or our service providers’ systems; however, we take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal information.
We restrict access to personal information to our employees, contractors and agents who are required to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, up to and including termination, as well as civil action prosecution, if they fail to meet these obligations.
You are responsible for keeping any passwords secret to prevent unauthorized access to and use of any of the Services to which you have access. In addition, if you are an enterprise user, your Organization is responsible for ensuring that the system is configured to properly restrict access to information in accordance with its own privacy statement or policy, and that anyone with access to that information is covered by its privacy statement or policy.
CONTACTING US
If you have any questions or concerns about our privacy practices or about the personal information which you have provided to us, please contact our Privacy Officer by email at privacy@neontrain.com or write to:
NeonTrain Inc.
1697 Brunswick Street, Unit 2
Halifax, Nova Scotia, B3J 2G3, Canada
We will respond to your inquiry in a timely and complete manner.