In our mission to make education better for everyone and track the participation and progress of the learners, the Dual Code learning environment collects information on users who visit sites powered by Dual Code.

This Privacy Policy will help you better understand how this information is collected, used, and stored, and how you can request access to it.

We collect and use information about:

• Account Owners who represents individuals or organizations that sell courses via the OCI Marketplace
• Account Administrators who represent Account Owners and create and teach courses
• Learners who enroll in courses

Our Values

Trust is the foundation of the OCI platform and includes trusting us to do the right thing with your information. Three main values guide us as we develop our products and services. These values should help you better understand how we think about your information and privacy. 

Your information belongs to you 

We carefully analyze what type of information we need to provide our services, and we try to limit the information we collect to only what we really need. Where possible, we delete or anonymize this information when we no longer need it. When building and improving our products, our engineers work closely with our privacy and security teams to build with privacy in mind. In all of this work our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit. 

We protect your information from others 

If a third party requests your personal information, we will refuse to share it unless you give us permission or we are legally required. When we are legally required to share your personal information, we will tell you in advance, unless we are legally forbidden. 

We help clients and partners meet their privacy obligations 

Many of the clients and partners using a site powered by OCI do not have the benefit of a dedicated privacy team, and it is important to us to help them meet their privacy obligations. To do this, we try to build our products and services so they can easily be used in a privacy-friendly way. We also provide documentation covering the most important privacy topics, and respond to privacy-related questions we receive.

Why we process your information

We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process your enrollment in a course delivered on a site powered by OCI and to track your participation and progress in that course), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, your workplace to track your compliance). These reasons are called “legitimate interests.” These “legitimate interests” include:

• Enrolling you in courses (or in some cases, preventing erroneous enrollment)
• Tracking your participation and progress in courses, including compliance
• Issuing learning records and certificates of completion
• Preventing risk and fraud
• Providing reporting and analytics

We only process personal information for these “legitimate interests” after considering the potential risks to your privacy, and by offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.

One of the ways in which we are able to help clients using our platform is by using techniques like “machine learning” (referred to as “automated decision-making”) to help improve suggestions for courses offered by our clients, partners, or other 3rd parties. When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don’t have significant privacy implications (for example, suggesting a course to you based on other courses you have already enrolled in).

We may process your personal information where you have provided your consent. In particular, where we cannot rely on an alternative legal basis for processing, where your data is sourced and it already comes with consent or where we are required by law to ask for your consent.

Your rights over your information

We believe you should be able to access and control your personal information no matter where you live. Depending on how you access a site powered by OCI, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information (for example, direct marketing). We will not charge you more or provide you with a different level of service if you exercise any of these rights.

If you are registered on a site that is powered by OCI and wish to exercise these rights over information about your account, you need to directly contact the owner of the site you are registered with. Dual Code simply hosts the platform on their behalf, and cannot decide how to process their information, which varies based on their jurisdiction, their relationship with you (for example, if they are your current employer or former employer), and various other reasons. We will of course help our clients to fulfill these requests by giving them the tools to do so and by answering their questions.

If you are not happy with their response to your request, you can contact us for further assistance to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time. Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond.

Where we store your information

We are a Canadian company. All of our data is stored in Canada. We abide by Canadian privacy laws and regulations, including PIPEDA, PHIPA, and others based on the various Canadian jurisdiction. We require our clients and partners to do the same.

How we protect your information

Our teams work tirelessly to protect your information, and to ensure the security and integrity of our platform. However, we all know that no method of transmission over the Internet and method of electronic storage can be 100% secure. This means we cannot guarantee the absolute security of your personal information. You can find more information about our security measures at https://www.dualcode.com/security.

How you can reach us

If you would like to ask about, make a request relating to, or complain about how we process your personal information, please contact us via email, or mail us at the address below.

By email:    privacy@dualcode.com

By mail:

Dual Code Inc. ATTN: Chief Privacy Officer 300 March Road 4th Floor Kanata, ON   K2K 2E2 Canada