Policy

What information do we collect and what do we do with it?

1. When you enroll in the 12 Million Women community we collect basic personal information required to identify you and differentiate you from other members. This includes your name and email address. If you have chosen to use social login (e.g. Facebook, Twitter sign-on) it may also include information collected and disclosed by the social platform in support of login functionality. 

   The collection of this information serves the following purposes:

   • Member identity including verifying that a member meets all membership requirements

   • Creation of, access to, and management of member account

   • Community interactions 

   • Tracking of member preferences and progress

   • Delivery of personalized professional learning and community experiences

   • Collection and processing of membership payments and other transactions

   • Issuing of credentials upon course completion

   We collect and store your information securely in our online learning platform supported by CIrcleCo Inc. Your information is used to support personalized learning and community experiences. We also use this information to contact you with information about community offerings, interactions, and experiences unless you tell us not to. 

   CircleCo Inc. stores personal information on your and our behalf in their secure environment.  This does mean that information you give us may be transferred outside your region. CircleCo Inc. also collects information on our behalf regarding your community interactions and use of community services such as messaging, forms, comments, blog posts etc. CIrcleCo Inc. may retain a copy of your information to fulfill its legal and regulatory obligations. 

   If you have chosen to be kept informed about the community we may also use your information to contact you via email with details of community experiences we believe will be of interest to you. We may disclose your information and any provided preferences to our email provider in support of relevant communications. You can change your preferences with respect to email marketing at any time. 

   When you make purchases we are also required to collect data that supports payment processing which may include credit card details, billing address, telephone number and any other information required by our payment processor in support of a successful transaction. We may disclose personal, contact, and payment information to our payment processor as required to fulfill transactions for community membership and related transactions. 

   We may disclose personal information to our certification provider when you have completed courses for which certificates or digital credentials are issued.  

   We may collect, use, or disclose personal information without your knowledge in the following circumstances:

   • When the collection, use, or disclosure is required by law

   • When you have violated the terms of this policy or our Terms of Service

   • In an emergency that threatens an individual's life, health or personal security

   • When the personal information is available from a public source

   • When we require legal advice from a lawyer

   • For the purposes of collecting a debt

   • For the purpose of fraud protection

   • During the investigation of a suspected or anticipated breach of an agreement or contravention of the law

   We will never sell your information under any circumstance.

   For more information on privacy considerations with respect to the Circle experience please consult their Privacy Policy found here. For European citizens further details can be found here including information about how Circle supports your rights with respect to privacy. 

   The legal bases we rely on to process your personal information depends on the services you use and how you interact with them. They primarily include:

   • Contractual Necessity: we process personal information to perform the services you requested under our Terms of Service or other similar contractual agreements with you. For example, we process personal information to set up and maintain your account; process your purchases; authenticate users; provide user-experience features (like saving your preferences); monitor and analyze the services; detect and prevent fraud, or other similar misuse; and contact you about your account, transactions, or other updates. We also rely on performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries, and notifying you about changes to our applicable terms or policies.

   • Legitimate Interests: we process personal information as needed for our business purposes, balanced against the potential impact on your privacy rights. This includes many common purposes that you’d reasonably expect, such as to: communicate with you, respond to your requests, or provide you with updates and information; better understand our users and their preferences; personalize your experience, save your preferences, authenticate our users, and provide similar user experience features; develop, deliver, and improve the services and other offerings (some of which may be offered in partnership with other parties); manage and customize advertisements or promotional offers; secure and protect the services; prevent fraud and illegal activity; and support internal purposes such as auditing and data analysis.

   • Legal Obligations: we process personal information when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes.

   Consent: we process personal information when you provide us with your consent to do so. You aren’t required to provide consent if you do not want your personal information to be processed for the requested purposes, and you may withdraw your consent at any time.

What should I know about consent?

As part of our registration process you will be asked to indicate your consent for our collection, use, disclosure, and storage of personal information by agreeing to this policy. If you do not consent to the collection of personal information do not complete the registration process. 

By enrolling with 12 Million Women and submitting your consent you represent that you are at least the age of 18 in your state, territory, country or province of residence as may apply.  If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@12millionwomen.com. 

Express consent for email marketing is collected through an opt-in workflow supported by our email provider. If you do not consent to email marketing, do not complete the opt-in workflow. Email marketing preferences can be changed at any time.

You may withdraw your consent for our collection, use, disclosure, and storage of your personal information at any time. Note that withdrawal of this consent may prevent our delivery of community experiences. In the event that community participation and experiences are compromised by such withdrawal, we may offer a refund for applicable incomplete services. To withdraw your consent contact us at info@12millionwomen.com. ​​

Upon written request and authentication of identity, we will provide you with your other personal information under our control, information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We will make the information available within 30 days or provide written notice where additional time is required to fulfill the request.

In some situations we may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal information.

Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

What safeguards protect my information?

12 Million Women, CIrcleCo Inc., and our third-party service providers take great care to safeguard your information. Collectively, we take reasonable precautions and follow industry best practices to prevent loss, misuse, unauthorized access, inadvertent and unauthorized disclosure, alteration or destruction of your personal information.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption.  Although no method of transmission over the Internet or electronic storage is 100% secure, our payment processor follows all PCI-DSS requirements and implements additional generally accepted industry standards.

What should I know about tracking?

CIrcleCo Inc. uses cookies or similar tracking technologies on the community platform. This information can be used to track your session and community engagement. Cookies may also be used to support a personalized learning experience. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer. For more information about how CircleCo Inc. uses cookies, please see their Cookies Policy.

CircleCo Inc. may also track specific interactions with the platform including pages visited, course material accessed or viewed, and community engagement. These data are made available to 12 Million Women for our use in providing a top quality community experience. Session information is anonymous in this case.

How long will you retain my information?

We will retain your information as long as it is required to serve your community experiences. Your account information is retained as long as your account has an active subscription that is fully paid. Should an account be in arrears we reserve the right to suspend the account until payment is received. A suspended account where no payment has been received for 12 months will be deleted. 

If you have created an account and paid the required subscription fee but have never undertaken a community engagement your account will remain active for a period of 12 months from the last date of access. Dormant accounts will be deleted following 12 months of inactivity. 

If you cancel your subscription, your account details will be retained until your previously paid subscription period has expired. Following subscription expiry, your account will be deleted. 

If your information is disclosed to a third party in support of your community and learning experience their records are governed by their own retention policies. 12 Million Women does not have the ability to control data handling or processing after disclosure. Make yourself familiar with our third-party partner Privacy Policies as below:

Stripe

ConvertKit  

We regularly review our third parties for compliance with Canadian and international privacy regulations.

My personal information is not accurate, how can I change it?

We rely on you to submit accurate personal information and to manage this personal information using your account features. In the event of personal information that is inaccurate and uneditable please contact us at info@12millionwomen.com so that we may support you further. 

All personal information is always available for you to reference in your CircleCo Inc. profile.

Who can I contact if I am concerned about my personal information?

We would be happy to hear any concerns you may have at any time. Please contact us at info@12millionwomen.com and our Privacy Officer will respond. In the event that our response is unsatisfactory you may also contact the Information and Privacy Commissioner of British Columbia.

Will I be aware if this policy changes?

We reserve the right to modify this policy at any time to ensure the privacy of our members is always addressed through implementation of best practices. In the event that this policy changes you will be notified of the change. The current version of the policy can always be verified by the version and date.