-Privacy Policy-

Updated May 17, 2018

ABOUT US

The Surge Group and our brands (SquarePeg Leadership and Business Road Mapping) (“we”, “us”, “our” or “Company”) are a provider of leadership coaching, business coaching and facilitation.  We provide leadership and business coaching information via face-to-face connection and via our websites and online (e-courses, e-Newletters and other products and services). 

We care about protecting the personal information of our customers and visitors (collectively, our “Users”) who use our websites, products or services (“Services”).  This privacy policy provides details about how your personal information is collected, shared and used by us. 

ACKNOWLEDGEMENT AND ACCEPTANCE OF TERMS

The Surge Group and our brands are committed to protecting your privacy. This privacy policy sets forth our current privacy practices with regard to the information we collect when you or your computer interact with our websites. By accessing our websites you acknowledge and fully understand Company’s privacy policy and freely consent to the information collection and use practices described in our websites' privacy policy.

WHAT INFORMATION IS COLLECTED

In the course of your use of the Services, we obtain the following information about you as described below. We collect this data for the purposes described under “How We Use Your Information”.  Data is collected directly from our websites’ server logs, from cookies, from the User, including responses to surveys and questionnaires and content voluntarily shared in forums.

SIGNING UP FOR SERVICES; USER INFORMATION

  • Information you provide prior to any registration process, such as your email when you provide it to us;
  • Information that you provide during any registration process, including in connection with a co-branded offer (such as your name, company name, email address, phone number, billing address or credit card information, geographic location and industry), when you call or email us (for support or otherwise) or when you use our products or services; and
  • Payment information that you provide to us (by way of our Services or otherwise) when you purchase some of our products and services, including credit card data.
  • Throughout the websites there may be forms to request information and purchase or obtain products and/or services. These forms typically ask for contact information (such as your phone, address or e-mail address), financial information (such as your credit card numbers), and demographic information (for example, company product categories, areas of interest, location, etc.) Information from these forms is used to deliver the information, products and/or services that you request. It may also be used to notify you of future products, services and/or opportunities that may be of interest to you. When completing these forms, please do not supply another person’s personal data to us.

USE OF SERVICES, WEBSITE VISITS AND SUPPORT

Data relating to your online activity on our websites with respect to our Services, including the following:

  • IP address
  • browser type and version
  • geographic location
  • pages you view
  • how you got to our Services and any links you click on to leave our Services
  • when you update your information, communicate with us, or order new Services
  • metadata about your use of our Services and your emails you send (including clicks and opens)
  • your interactions with any videos we offer
  • issues you encounter requiring our support or assistance
  • any device or other method of communication you use to interact with the Services
  • Your telephone conversations with us (which we may monitor or record).
  • This data is stored in a variety of places within our infrastructure, and/or with our third party service providers, including system log files, back end databases and analytics systems.

USE OF COOKIES

  • We do not use cookies to collect personal information.
  • We may use cookies to personalize or enhance your user experience.

A cookie is a small text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. Hence, this simplifies the process of delivering relevant content and eases site navigation by providing and saving your preferences and login information as well as providing personalized functionality.

Company reserves the right to share aggregated site statistics with partner companies, but does not allow other companies to place cookies on our websites unless there is a temporary, overriding customer value (such as merging into our websites with a site that relies on third-party cookies).

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you reject cookies by changing your browser settings, then be aware that this may disable some of the functionality on our websites.

SOCIAL MEDIA

  • Information from third party social networking sites, including information that social networking sites provide to us if you use your credentials at such social networking sites to log into some of our Services (such as your name and email address to pre-populate our sign-up form).
  • The information you allow us to access varies by social networking site, and depends on the level of privacy settings you have in place at the social networking site. You can control and find out more about these privacy settings at the applicable social networking site.

USE OF WEB BEACONS OR GIF FILES

Company web pages may contain electronic images known as web beacons – sometimes also called single-pixel gifs – that allow Company to count users who have visited those pages and to deliver co-branded services. Company may include Web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon.

Some of these web beacons may be placed by third party service providers to help determine the effectiveness of our advertising campaigns or email communications. These web beacons may be used by these service providers to place a persistent cookie on your computer. This allows the service provider to recognize your computer each time you visit certain pages or emails and compile anonymous information in relation to those page views, which in turn enables us and our service providers to learn which advertisements and emails bring users to our websites and how they use the site. Company prohibits web beacons from being used to collect or access your personal information.

OTHER SOURCES

  • Information you provide to us at seminars or to our partners;
  • Information you provide to us in surveys;
  • Information that is publicly available; and
  • Information you consent to us receiving from third parties.

HOW WE USE YOUR INFORMATION

We have a legitimate interest in running a successful and efficient business and in providing you with Services and useful content, and we use the information we collect, both on its own and combined with any other information we collect about you, for the following purposes:

  • To provide the requested Services to you;
  • To provide you with useful content;
  • To ensure the proper functioning of our Services
  • To offer and improve our Services;
  • To provide you with requested information or support
  • To facilitate your movement through our websites or your use of our Services;
  • To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law);
  • To advertise and market third party products and services (such advertisement is only performed with your permission where your consent is required by applicable law)
  • To diagnose problems with our servers or our Services;
  • In connection with our security and compliance programs;
  • To administer our websites;
  • To communicate with you;
  • To target prospective customers with our products or services (such targeting is only performed with your permission where your consent is required by applicable law);
  • To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
  • As otherwise described in this privacy policy.

We also use the information we receive in aggregated and anonymized formats to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of users that have been exposed to, or clicked on, our websites or evaluated or purchased our products and services.

Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services.

We will not disclose personally identifiable information we collect from you to third parties without your permission except to the extent necessary including:

  • To fulfill your service requests for products or services.
  • To protect ourselves, our customer or our vendors from liability or to defend our rights, including investigations of fraud or misconduct.
  • To third parties who have agreed in writing to maintain such information in confidence and use such information solely in performance of services to us.
  • To respond to legal process or comply with law, including subpoenas.
  • To entities under common ownership or control with us or to our owners, or
  • In connection with a merger, acquisition, or liquidation of the company.

PUBLIC FORUMS

Our sites may make Web forums available to its users.  Any information that you, the user chooses to disclose in these areas becomes public information, and you should exercise caution when deciding to disclose personal or business information.

PARTICIPATING MERCHANT POLICIES/THIRD PARTY SERVICE PROVIDERS

Some of our Services provide links to other websites, including vendor sites and merchant sites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information.

You may also log in to some of our Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you with the option to share certain personal information with us, such as your name and email address to pre-populate our sign up form. For example, if you take advantage of certain of our social media features, such as the Facebook Like button, and widgets, such as the “Share This” button or interactive mini-programs that may run on our sites, the applicable social networking sites may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable it to function properly.

EMAIL AND SPAM POLICY

We are committed to keeping your e-mail address confidential. We do not sell, rent or lease our subscription lists to third parties, and we will not provide your personal information to any third-party individual, government agency or company at any time unless compelled to do so by law. We will use your email address solely to provide timely information about our brands and our programs and services. We will maintain the information you send via email in accordance with applicable international law.

In compliance with the CAN-SPAM Act, GDPR, and CASL all email sent from our organization will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further email communication from us.

CHOICE/OPT-OUT/UPDATES

EMAIL

Users of our websites can opt out of receiving communications from us.  If you no longer wish to receive further communications or need to change or modify information previously provided, please email  privacy(at)surgestrategies(dot)com or call +1.250.412.7819

You may also opt out of receiving email communications by clicking the unsubscribe link in any non-transactional email from us.

Some communications from us are considered transactional or service communications (for example, important account notifications and billing information), and your account(s) for Company’s products and services are provided to you upon the condition that you receive these communications from us. You must cancel your account(s) for Company’s products and services, as applicable, if you do not wish to receive any transactional or service communications. To cancel your account(s), please contact privacy@surgestreagies.com. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.

INFORMATION FROM THIRD PARTIES

To manage the information we receive about you from a social networking site or other third parties (if applicable), you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this privacy policy and the information the third party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third party site will not apply to our use of the information we have collected directly through our Services.

UNAUTHORIZED ACCOUNTS

If an account or profile was created without your knowledge or authorization, please contact customer support at the brand on which the account or profile is located to request removal of the account or profile.

UPDATES

If you would like to access, correct, amend or delete any personally identifiable information we store about you, register a complaint, or simply want more information, contact us at privacy(at)surgestrategies(dot)com. 

RETENTION OF PERSONAL INFORMATION

We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than seven years following the later of (i) the date on which you terminate your use of the Services or (ii) May 25, 2018, unless we are otherwise required by law or regulation to retain your personal information for longer.

HOW WE PROTECT INFORMATION

We use physical, electronic and managerial procedures to protect information collected online including firewalls to protect the loss, misuse and alteration of the information under our control. This security program is appropriate to the size, scope and type of our business, the resources available to us, the amount of stored data, and the need for security and confidentiality of the personal information we store. No security system is impenetrable. The use of these security measures is not a guarantee that information supplied over the Internet will not be intercepted. You can help us by taking precautions to protect your personal information when you are on the Internet and only disclose information that you want made public. Change your passwords often using a very strong password and make sure to use a secure web browser.

For the purposes set out in this privacy policy, personal information may be transferred to, processed, stored and accessed by us, our affiliates and third parties in Canada and in other jurisdictions where we or they operate. Courts and other authorities in these jurisdictions may, in certain circumstances, be entitled to access your personal information. By using the websites, you consent to this transfer, processing, storage and access of your personal information in and/or outside of the jurisdiction in which you reside.

YOUR RIGHTS

Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

  • The right to access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to object to processing
  • The right to data portability
  • The right to complain to a supervisory authority
  • The right to withdraw consent

If you wish to exercise any of these rights, you may contact privacy(at)surgestrategies(dot)com or +1.250-412-7819.

CHILDREN

Our Services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us. If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files.  If you are a child under 18, please do not register for any of our services or provide us any information about yourself (such as your name, email address or phone number).

CHANGES TO THIS POLICY

Company has the discretion to occasionally update this privacy policy. When we do, we will also revise the “updated” date at the top of this privacy page. We encourage you to periodically review this privacy policy to stay informed about how we are helping to protect the personal information we collect. Your continued use of the service constitutes your agreement to this privacy policy and any updates.  Those who choose to access our sites from other jurisdictions do so on their own volition and are responsible for compliance with applicable local laws.

TRANSLATIONS

This privacy policy is executed in English. You agree and acknowledge that you have reviewed this privacy policy in English. To the extent that any translations of this privacy policy are provided, they are solely for convenience and is of no binding effect. The English language version of this privacy policy shall control.

CONTACTING US

If you have questions regarding our privacy policy, its implementation, failure to adhere to this privacy policy and/or our general practices, please contact us at privacy(at)surgestrategies(dot)com or send your comments to:

The Surge Strategies Group
Attention: Privacy Policy Personnel
671 Steamer Drive
Victoria, BC V9E 2A1

Company will use commercially reasonable efforts to promptly respond to and resolve any problem or question.

For the purposes of the European Union’s General Data Protection Regulation 2016/679 or GDPR, The Surge Group and each of our brands for which you have signed up for a product or service are the data controller.