Sam Rafoss, CEO + Founder
Sober and Serene
#176 – 919 Centre Street NW
Calgary, AB T2E 2P6
ISSUED BY: Sober Women Success
EFFECTIVE DATE: January 1, 2021
Privacy of personal information is an important principle of Sober and Serene. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for Your company name services that we provide. We also are diligent at being open and transparent as to how we handle personal information. This document describes our privacy policies.
1.2 Effective Date and Revisions
1.3 Personal Information
Personal information includes any factual or subjective information, recorded or not, about an
identifiable individual. This includes information in any form, such as:
Age, name, ethnic origin, sexual orientation, or blood type
Anthropometric measurements including weight, body fat, waist and hip circumference
Medical records, health conditions or concerns
Opinions, evaluations, comments, social status, or disciplinary actions; and
Intentions (for example, to change jobs).
Personal information does not include the name, title, business address or telephone number of an employee of an organization and thus is not protected by privacy legislation nor covered by this policy.
1.4 About Sober and Serene
Sober and Serene was established in 2020 to educate and coach individuals, groups and corporations about sobriety, metaphysics, holistic health and wellness, and related business and marketing services for those that engage our services.
The purpose of this document is to outline the policies in effect that govern Sober Women Success collection, storage, retention, use and disclosure of personal information. These rules are in place to protect Sober Women Success, our participants, clients, and consultants. Failure to comply with this policy exposes Sober Women Success to a breach of confidentiality resulting in potential legal liability and loss of confidence.
This policy applies to the staff and volunteers and to contractors and consultants that may provide services to Sober Women Success on occasion.
4.1 We Collect Personal Information:
The collection of personal information is limited to that which is necessary for our purposes.
Sober Women Success collects and uses personal information for new clients and for maintaining a list of group program participants.
This allows us to monitor progress and results, participation and retention rates.
Sober and Serene uses and discloses personal information only for purposes for which we have consent (implied or written), or as required by law. If requested, Sober Women Success discloses our participants’ names to the organization contracting Sober Women Success for invoicing purposes.
Sober and Serene endeavors to maintain accurate and up-to-date records.
Information We May Collect
We collect personal information from you so that we can provide you with a positive experience when utilizing our Website or content. We will only collect the minimum amount of information necessary for us to fulfill our obligation to you. We may collect:
A name and an email address so we can deliver our newsletter to you – you would be affirmatively consenting to this by providing this to us in our contact forms.
Billing information including name, address and credit card information so that we can process payment to deliver our products or services to you under our contractual obligation.
A name and an email address if you complete our contact form with a question. We may send you marketing emails with either your consent or if we believe we have a legitimate interest to contact you based on your contact or question.
Please note that the information above (“Personal Data”) that you are giving to us is voluntarily, and by you providing this information to us you are giving consent for us to use, collect and process this Personal Data. You are welcome to opt-out or request for us to delete your Personal Data at any point by contacting us at firstname.lastname@example.org
If you choose not to provide us with certain Personal Data, you may not be able to participate in certain aspects of our Website or content.
Other Information We May Collect:
Anonymous Data Collection and Use
To maintain our Website’s high quality, we may use your IP address to help diagnose problems with our server and to administer the Website by identifying which areas of the Website are most heavily used, and to display content according to your preferences. Your IP address is the number assigned to computers connected to the Internet. This is essentially “traffic data” which cannot personally identify you but is helpful to us for marketing purposes and for improving our services. Traffic data collection does not follow a user’s activities on any other websites in any way. Anonymous traffic data may also be shared with business partners and advertisers on an aggregate basis.
Use of “Cookies”
We may use the standard “cookies” feature of major web browsers. We do not set any personally identifiable information in cookies, nor do we employ any data-capture mechanisms on our Website other than cookies. You may choose to disable cookies through your own web browser’s settings. However, disabling this function may diminish your experience on our Website and some features may not work as intended.
What We Do with Information We Collect
We may contact you with information that you provide to us based on these lawful grounds for processing:
We may contact you if you give us your clear, unambiguous, affirmative consent to contact you.
We will contact you under our contractual obligation to deliver goods or services you purchase from us.
Legitimate Interest. We may contact you if we feel you have a legitimate interest in hearing from us. For example, if you sign up for a webinar, we may send you marketing emails based on the content of that webinar. You will always have the option to opt out of any of our emails.
We will use the Personal Data you give to us in order to process your payment for the purchase of goods or services under a contract. We only use third party payment processors that take the utmost care in securing data and comply with the GDPR.
Targeted Social Media Advertisements
We may use the data you provide to us to run social media advertisements and / or create look-alike audiences for advertisements.
Share with Third Parties
We may share your information with trusted third parties such as our newsletter provider in order to contact you via email, our merchant accounts to process payments, and Google / social media accounts in order to run advertisements and our affiliates.
Viewing by Others
Note that whenever you voluntarily make your Personal Data available for viewing by others online through this Website or its content, it may be seen, collected and used by others, and therefore, we cannot be responsible for any unauthorized or improper use of the information that you voluntarily share (i.e., sharing a comment on a blog post, posting in a Facebook/LinkedIn group that we manage, sharing details on a group coaching call, etc.).
4.2 We Protect Personal Information:
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Paper copy is kept in a locked file cabinet and/or locked office, in a supervised area.
Passwords are used on computers to protect electronic data, in a supervised area.
Paper information is transmitted through sealed, addressed envelopes or boxes by postal service or in person.
Our website is protected by security safeguards appropriate to the sensitivity of the information with the proper firewalls and virus protection in place.
Verbal personal information is collected and used in such a manner that the information is not overheard by persons other than the staff.
External consultants and agencies with access to personal information must enter into privacy agreements with us.
To use certain features of the Website or its content, you may need a username and password. You are responsible for maintaining the confidentiality of the username and password, and you are responsible for all activities, whether by you or by others, that occur under your username or password and within your account. We cannot and will not be liable for any loss or damage arising from your failure to protect your username, password or account information. If you share your username or password with others, they may be able to obtain access to your Personal Data at your own risk.
You agree to notify us immediately of any unauthorized or improper use of your username or password or any other breach of security. To help protect against unauthorized or improper use, make sure that you log out at the end of each session requiring your username and password.
We will use our best efforts to keep your username and password(s) private and will not otherwise share your password(s) without your consent, except as necessary when the law requires it or in the good faith belief that such action is necessary, particularly when disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.
How You Can Access, Update or Delete Your Personal Data
You have the right to:
· Request information about how your Personal Data is being used and request a copy of what Personal Data we use.
· Restrict processing if you think the Personal Data is not accurate, unlawful, or no longer needed.
· Rectify or erase Personal Data and receive confirmation of the rectification or erasure. (You have the “right to be forgotten”).
· Withdraw your consent at any time to the processing of your Personal Data.
· Lodge a complaint with a supervisory authority if you feel we are using your Personal Data unlawfully.
· Receive Personal Data portability and transference to another controller without our hinderance.
· Object to our use of your Personal Data.
· Not be subject to an automated decision based solely on automatic processing, including profiling, which legally or significantly affects you.
We collect this information:
• Directly from you when you provide it to us
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies
• From third parties, for example PayPal (https://www.paypal.com/us/webapps/mpp/ua/privacy-full), Mailchimp https://mailchimp.com/legal/privacy/
Survey Monkey (https://www.surveymonkey.com/mp/legal/privacy-policy/)
You may unsubscribe from our updates or e-newsletters at any time through the unsubscribe link at the footer of all email communications. If you have questions or are experiencing problems unsubscribing, please contact us at email@example.com
We take commercially reasonable steps to protect the Personal Data you provide to us from misuse, disclosure or unauthorized access. We only share your Personal Data with trusted third parties who use the same level of care in processing your Personal Data. That being said, we cannot guarantee that your Personal Data will always be secure due to technology or security breaches. Should there be a data breach of which we are aware, we will inform you immediately.
We have a no spam policy and provide you with the ability to opt-out of our communications by selecting the unsubscribe link at the footer of all e-mails. We have taken the necessary steps to ensure that we are compliant with the CAN-SPAM Act of 2003 by never sending out misleading information. We will not sell, rent or share your email address.
Third Party Websites
We may link to other websites on our Website. We have no responsibility or liability for the content and activities of any other individual, company or entity whose website or materials may be linked to our Website or its content, and thus we cannot be held liable for the privacy of the information on their website or that you voluntarily share with their website. Please review their privacy policies for guidelines as to how they respectively store, use and protect the privacy of your Personal Data.
Children’s Online Privacy Protection Act Compliance
We do not collect any information from anyone under 18 years of age in compliance with COPPA (Children’s Online Privacy Protection Act) and the GDPR (General Data Protection Regulation of the EU). Our Website and its content are directed to individuals who are at least 18 years old or older.
Notification of Changes
Data Controller and Processors
We are the data controllers as we are collecting and using your Personal Data. We use trusted third parties as our data processors for technical and organizational purposes, including for payments and email marketing. We use reasonable efforts to make sure our data processors are GDPR- compliant.
4.3. We Retain and Destroy Personal Information Records:
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services we provided to you and for our own accountability to external regulatory bodies.
In compliance with the requirements of other legislation, we keep our participants’ and clients’ files and records for 10 years. We keep any personal information relating to our general correspondence (i.e. email correspondence, seminar materials, informational handouts and marketing activities) for about 12 months after a seminar, client consultation or marketing activity is completed. You may ask us, in writing, to restrict our uses and disclosures of your personal information at any time. We will discontinue to use or to disclose your personal information after a written revocation of your implied or informed consent is received, unless we have already acted in reliance upon this consent, or as directed by legal requirements.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when hardware is discarded, we ensure that information on the hard drive is destroyed.
4.4. You Can Look at Your Information:
Upon request, you have the right to see what personal information we hold about you. We will need to confirm your identity, if we do not know you, before providing you with this access. We may ask you to put your request in writing. If, for legal reasons, we cannot give you access, we will notify you within 30 days, and provide the reason, as best we can, why we cannot give you access. If you believe there is a mistake in the information, we have about you, you have the right to ask for it to be corrected. We may ask you to provide documentation that our files are incorrect. Where a mistake has been made, we will make the correction.
4.5. Do You Have A Question?
Our Privacy Officer, Sam Rafoss, can be reached to answer any questions or concerns you might have at:
Sam Rafoss, CEO
Sober Women Success
#176 – 919 Centre Street NW
Calgary, AB T2E 2P6
If you wish to make a formal complaint about our privacy practices or the application of those practices, you may make it in writing to our Privacy Officer, who will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and explanation in writing.
Anyone found to have violated this policy may be subject to disciplinary action, up to and including termination. Use of any personal information in the possession of or under the control of Your company name for illegal activity is grounds for immediate dismissal of office, and we will cooperate with any legitimate law enforcement activity.
6.0 Further Information
This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 KENT STREET, PLACE DE VILLE, TOWER B, 3RD FLOOR | OTTAWA, ONTARIO | K1A 1H3
PHONE (613) 995-8210 | TOLL-FREE 1-800-282-1376
FAX (613) 947-6850 | TTY (613) 992-9190
WEB SITE: www.privcom.gc.ca
Last Updated: June 24, 2021