Privacy Policy 

Spirit of Math Schools Inc. (the “Company”) is an after-school enrichment program that operates corporately owned campuses in Canada and the United States and grants franchises for the operation of additional Spirit of Math campuses in Canada. We also offer a mobile application, the Drill App,. The Company is committed to helping ensure the privacy of those who enroll in its program, use its Mobile App, and/or those who visit its website (together, our “Services”).  

The purpose of this Privacy Policy is to tell you what personal information we collect about users of our Services, including students and their parents or guardians, how we use it, whether we disclose it to anybody else, how long we keep it, and how you can request access to your personal information or obtain more information about the Company’s privacy policies and procedures.

By using our website or Services, or by choosing to give us personal information, you consent to this Privacy Policy and the processing of your personal information it describes.    

If you do not agree with any terms of this privacy policy, please exercise the choices we describe in this policy, or do not use the Services and do not give us any personal information.  

1. What Personal Information Does the Company Collect and Why? 

The Company, through its network of company-owned and franchised local Spirit of Math campuses, collects personal information of its students in the normal course of doing business. “Personal information” is any information that could be used to identify an individual, such as your name, contact information, and payment information (“Personal Information”).  Depending on the nature of your interaction with us, we may collect personal information including the following:

• Name, address, and telephone and facsimile numbers of a student and their parent or guardian;

• E-mail address;

• Payment information, including credit card numbers where used as a form of payment;

• Educational background, records and related information;

• Medical information that you may provide; and

• Other information which you choose to provide to us.  

If you use our Mobile App, we may collet information such as your name, email, grade level, location, drills you attempt using the App and their performance on them (e.g. time, score), for practice and class assignments. If you use our Mobile App as part of a school, we also get the school and classes they attend, who their teachers  are.

We may collect this Personal Information directly from you, for example, when you complete a form we provide, register for our Services, provide it to us using our Mobile App, or otherwise communicate with us. We may also use technologies such as cookies to collect information automatically when you visit our Website. For more information on how we use technology to collect information, please see How We Collect Information using Technologies, below.    

Providing your Personal Information, either in person, by telephone, or online, constitutes your consent to the collection, use and disclosure of such Personal Information by the Company for the purpose of providing the relevant services.  

For minors, Personal Information is collected only with the consent of their parent or guardian. If you are a minor, you must have the permission of your parent or legal guardian to use our Services, or provide us with your personal information.  

Consent of your parent or legal guardian to use our Services, or to provide us with Personal Information. Completion of our student Registration Form indicates your consent, as a parent or guardian, to the collection of your child’s as a student Personal Information for the purposes outlined in this Privacy Policy.

2. What Personal Information Does the Company Collect and Why? 

The Company may use your Personal Information to provide you with our Services, including our program services, our Mobile App, enrichment tools and information we think may interest you. For example, the Company may use personal information to:

• Provide you and your minor student the Services you request. For example, if you make a purchase, we use the payment information you provide to process your payment;  

• Contact you to discuss your student’s progress if you are a parent or guardian of a minor student;

• Provide you with information and updates regarding programs or materials that we or the local Spirit of Math Schools have to offer and which the Company and the local Spirit of Math campus think will interest you;

• Respond to your requests for information, services and products;

• For our internal record keeping,

• Manage, administer, maintain, service, collect and enforce any agreement we have with you,

• Improve the Company’s and the local Spirit of Math campus Services to better understand and meet educational enrichments needs, and to improve and/or develop new offerings and services;

• Investigate and settle any dispute or claim which relates to our Services, and/or any agreement we have with you,  

• Investigate security breaches or cooperate with authorities pursuant to a legal matter, and  

• For other purposes which are disclosed to you and to which you consent.

Please note our  Registration form requests permission to use students’ photographs for promotional and for training Purposes, which requires your initials as the parent or guardian for each purpose, along with your signature and the date. In limited circumstances, the Company may contact you and ask for your permission to use a name of a student in its marketing. This will only be done with your express consent and signature, and normally would be used only when listing awards and achievements, and for the use of a partial name in testimonials.

We may also anonymize, aggregate or otherwise strip any personal information or other information we collect of all personally identifying characteristics and may use or share that aggregated, anonymized data with third parties for any purpose we deem appropriate.

3. Does the Company Disclose Personal Information? 

The Company may, on occasion, share some or all of your Personal Information with third parties for the purposes set out above. For example, Personal information may be shared:

• With other Spirit of Math Schools or entities affiliated with the Company for the purposes of providing you with services and information;

• With third parties that provide the Company with services, such as processing and marketing, or otherwise assist us with processing the information for the purposes we describe in this Privacy Policy.

Additionally, the Company may disclose your Personal Information where and when required or permitted by law to do so. For example, we may disclose personal information to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; or (iii) to protect our rights, safety or property, or those of others.

Please note that your Personal Information will, upon any sale of all or a portion of the assets of the Company, be transferred to a purchaser agreeing to use your Personal Information for the same purposes outlined in this Privacy Policy. Similarly, in the event of the termination, dissolution, sale or reorganization of a local Spirit of Math campus/franchise, Personal Information will revert to the Company for potential transfer to a new Spirit of Math Campus.

Lastly, we may disclose personal information for other purposes which are disclosed to you, and to which you consent.  

4. How Does the Company Collect Information Using Technologies such as Cookies?  

 SECTION 5 – HOW WE USE COOKIES AND COLLECT INFORMATION USING TECHNOLOGY 

A cookie is a small file  which is placed on your computer or mobile device’s hard drive. Cookies and other  technologies can help analyze web traffic or let us know what portions of our site people visit and what features they use. We may use cookies and other technologies to collect information that helps us operate and understand the use of our website, such as your Internet Protocol ("IP") address or device ID, operating system, browser type, username, the pages of the website that you visit, the time spent on those pages, access dates and times, clicks, links used, and actions you take on our site, any errors you encounter, and general region derived from IP address.  

We use cookies and other technologies to identify which portions of our website and services are being used and how they are being used. This helps us analyze data about traffic on our website, correct any errors our users encounter, and improve our website and services in order to better meet user needs. We also use this information for statistical analysis purposes.  

You can choose to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Services.

5. How Does the Company Protect the Personal Information It Collects? 

The Company has implemented safeguards and security measures including physical, technological, and organizational protections to help protect your Personal Information from loss, theft, unauthorized access, disclosure, copying, use or modification. Security measures adopted by the Company include limiting the number of individuals with access to your Personal Information, to those needed to access the information for the purposes we describe in this Privacy Policy. All affiliates, suppliers, agents, employees and other parties performing services on our behalf who handle Personal Information are bound to maintain the confidentiality of all Personal Information and may not use the information for any unauthorized purpose.

However, even though we have taken steps to help protect the personal information in our control, you should know that we cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

5. How Long do we Keep Personal Information 

We retain personal information as long as necessary for the purposes we use it for. When personal information is no longer required, we will take steps to have the information deleted or destroyed.  

6. We may Transfer Personal Information to other Countries 

Personal information that we collect may be stored and processed in Canada and outside your jurisdiction of residence, in any other country in which we or our service providers maintain facilities, including in the United States, and other countries . Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.

By using our website and services or by providing us with personal information, you consent to any such transfer of information outside of your country. If you have any questions about our use of service providers outside of Canada, you may contact us using the information below.  

7. Your Privacy Rights and Choices 

You may request access to your personal information that we hold and to request a correction to it if you believe it is inaccurate, subject to exceptions in the applicable law. If you would like to have access to the personal information we have about you, or if you would like to have it corrected, please contact us using the contact information provided below. In some cases, we may not be able to allow you to access certain personal information in certain circumstances, for example, if it contains personal information of other persons, or for legal reasons.

Under certain circumstances and subject to applicable data protection laws, you may also be entitled to request additional information regarding our personal information governance practices, including details regarding what personal information is collected about you, the categories of persons who have access to your information, and how long your information will be retained for. You may also be entitled to request that we cease communicating your information, or de-index any hyperlink material attached to your name that provides access to your Personal Information by a technological means.

If you have a complaint about how your personal information is processed, or if you have questions regarding how to exercise your rights or if you wish to submit a request, please contact us using the contact information provided below.

You may choose to restrict the collection or use of your personal information in the following ways:

• You may write to or email us using the contact information below to withdraw your consent to us using your personal information for direct marketing purposes.  

• If you receive commercial email from us, you can also unsubscribe using the unsubscribe tool we provide in such messages.  

If you are a parent or legal guardian of a minor child whose information we process, you may also exercise these rights on behalf of your minor child.  

If you choose to withdraw consent from a processing of personal information we need to provide our Services, we may no longer be able to provide those Services to you.

Please note that to help protect against fraudulent requests related to your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. For example, we may require you to verify your identity before you access your personal information.

7. Changes to this Privacy Policy 

The Company may add, modify or remove portions of this Privacy Policy, as and when it deems necessary or appropriate. You should check this page from time to time to ensure that you are happy with any changes. You will be able to determine when this Privacy Policy was most recently modified by referring to the “last update” date appearing at the end of this document.  Your continued access to and/or use of our website or Services after any such changes constitutes your acceptance of, and agreement to this privacy policy, as revised.

8. Third Party Websites 

Our Services may link to websites that are operated by third parties we do not control. When you click on such a link, you will be directed away from our Services. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements. Once you leave our website to visit a third-party website, this Privacy Policy and our Terms of Service no longer apply. You should read the privacy policy and terms of use for each website you visit.  

9. Questions or Concerns about your Privacy 

If you have any questions or concerns about privacy, confidentiality, would like to submit a complaint, or would like to exercise your rights, such as a request for access to your Personal Information that has been handled by the Company, please contact the Company’s Privacy Officer at:

Spirit of Math Schools Inc.
Attn: Privacy Officer
101 – 1446 Don Mills Rd.,
Toronto, Ontario,
Canada M3B 3N3
  (416) 223-1985
  privacyofficer@spiritofmath.com