Privacy and Cookies Policy

Last Updated: September 15, 2022

The domain names www.rphconsultancy.com, www.rpheph.com, www.rphcch.com, www.royalpriesthood.group belongs to Royal Priesthood Group Consultancy Services Limited (henceforth referred to as the “RPH Group”).

In this Privacy & Cookies Policy (this “Policy”), ” Royal Priesthood Group Consultancy Services Limited “, “we“, “us” or “our” includes:

• RPH Educational and Professional Consultancy Hub
• RPH Corporate Consultancy Hub
• Royal Priesthood Group
• RPH Group
• RPHEPH
• RPHCCH

The RPH Group includes the following domains:
rpheph.com, rphcch.com, royalpriesthood.group

About Royal Priesthood Group Consultancy Services Limited
Our Commitment to Privacy
Collection and Processing of Personal Information
Third Parties and International Transfers
Retention of Personal Information
Your access to and control over Personal Information
Personal Information Security
Changes to our Privacy Policy
Additional terms for EEA and UK Customers
Additional Terms for State of California Customers

1. ABOUT ROYAL PRIESTHOOD GROUP CONSULTANCY SERVICES LIMITED

Royal Priesthood Group Consultancy Services Limited provides users services like Corporate Consulting, Career Consulting, Educational Consulting, International Student Placement Services, various educational programs like language training, Immigration assistance and services (collectively, the “Services”). We also provide the Services partially or fully by associating with various professionals who have expertise in those services, and through our partners, counsellors, business development associates and our website. To offer above mentioned Services, RPH Group collects your personal data, and this Privacy & Cookies Policy (“Policy”) sets out the manner RPH Group collects, uses, discloses, and otherwise manages personal data.

The changes made to this Policy go into effect as at the date listed above and your continued use of RPH Group’s services and/or website after this date will be subject to our updated Policy.

Royal Priesthood Group Consultancy Services Limited is the data controller responsible for your personal information under this Policy. This Policy applies to the operations of all network properties and services within the RPH GROUP family of websites, portals, social media platforms, etc., unless specifically indicated otherwise. The RPH GROUP is a collection of our consultancy services related properties, which offer various customized and value-added services.

Our postal address is:
8934 133 Ave
Edmonton- T5E 1C2
Canada
Phone: +1(780) 720 3282

RPH Group is the controller of your personal information, and is responsible for the collection, processing, and disclosure of your personal information as described in this Policy, unless expressly specified otherwise. If you have any questions about this Policy or want to exercise your rights under this Policy, please email us at privacy@rphconsultancy.com, or call us or write to our Data Protection Officer at the phone number or the address above.

2. OUR COMMITMENT TO PRIVACY

This Policy outlines our commitment to the privacy of all visitors to the RPH GROUP, and fully describes when, why and how we collect personal information (that you provide directly to us or is provided to us by third parties such as our partners, associates, agents, and counselors) in a secure manner. Your use of RPH GROUP Internet sites, portals and services are subject to the following Policy.

In this Policy, the term “personal data” or “personal information” means personal data or data that relates to an identified or identifiable person.

In addition, your use of our sites, portals and associated services constitutes your acceptance of these terms. If the changes are significant, you will be notified via email and/or a prominent notice on our website. However, we encourage you to review this Policy periodically to be informed of how Royal Priesthood Group Consultancy Services Limited and any affiliates and/or subsidiaries use your personal information. If you disagree with any changes to this Policy, you will need to stop using this website and deactivate your account(s), if applicable, as outlined below.

We may offer you the ability to connect with our websites or use our services and tools using a mobile device via a mobile optimized website. The provisions of this Policy apply to all such mobile access and use of mobile devices. This Policy will be referenced by all such mobile optimized websites.

Important Notes:

SPECIFIC TERMS FOR EUROPEAN UNION (“EU”), UNITED KINGDOM (“UK”) AND EUROPEAN ECONOMIC AREA (“EEA”) CUSTOMERS ONLY: Please note that the whole of this Policy applies to you, together with additional provisions which are specific to EEA and UK customers and can be found at Appendix 1.
SPECIFIC TERMS FOR CUSTOMERS FROM THE STATE OF CALIFORNIA ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to residents of California and can be found at Appendix 2.

3. COLLECTION AND PROCESSING OF PERSONAL INFORMATION

3.1. Personal information that we collect

We collect the personal data directly from you, about you from third parties such as our marketing affiliates and service providers used to verify your identity and prevent fraudulent activity, other RPH Group users and other RPH Group clients or customers that is necessary to carry out our business, provide the Service(s) you requested and to keep you informed of the latest news about our consultancy services and/or the RPH GROUP and through the use of cookies and metadata collected on our Website and the Services.

The personal information that we collect directly from you may include the following:

If you express an interest in obtaining additional information about our services, request client support, use our “Contact Us”, “Chat” or similar features, we generally require you to provide us with your contact information, such as your name, email address, phone number, and your country of residence. When you supply us with your contact information online, you will only receive contact from us regarding the matters relating to our consultancy services mentioned above;

Categories of Personal Data Collected	Specific Personal Data	Sensitive Personal Data	Source of Personal Data
Identifiers	Name, email address, phone number, billing or mailing address, IP address, date of birth.	National identification numbers and documents that may include your photograph and/or government identifier.	Directly from you, third parties on your behalf and as instructed by you, other RPH Group users and customers, our service providers, and affiliates.
Financial Information		Bank and credit account information, credit history as applicable, details of any transactions carried out using any of the Services.	Directly from you, third parties on your behalf and as instructed by you, recruitment partners, counsellors, other RPH Group users and customers, our service providers, and affiliates.
Health Information		Vaccination record, such as information about the date and type of vaccines you received and your personal health number.	Directly from you, third parties on your behalf and as instructed or permitted by you.
Internet or Other Similar Network Activity	Other information collected through Cookies and other tracking technologies as listed above and as described in the section below entitled “Our Use of Cookies and other Tracking Mechanisms”.		From you directly and our third-party analytic tools and cookies usage (See the section below entitled “Our Use of Cookies and other Tracking Mechanisms”).
Geolocation Data	Geolocation		Directly from you and/or [through your use of the Mobile Application] and/or our third-party analytic tools and cookies usage (See the section below entitled “Our Use of Cookies and other Tracking Mechanisms”).
Professional or Employment Information	Name and contact information, professional credentials and skills, educational and work history, salary, evaluations, references, interviews, certifications, disciplinary matters, and other information of the type included on a resume, curriculum vitae or cover letter.		Directly from you or when another party, such as a recruiter, counsellor, or external website, provides it to us.
Other categories	Any other information that you choose to provide to us (e.g., when you send us an email/otherwise contact us).		Directly from you, third parties on your behalf and as instructed or permitted by you.

We receive personal data about you from third parties, such as banking references, credit reporting agencies, affiliates, website hosts, live chat, and online support service providers, other RPH Group users, events vendors, and other third parties (e.g., entities that assist us in validating your identity, for risk assessment purposes, for fraud prevention, etc.). We may combine this information with other information that we collect about you. We, and our third party service providers, automatically collect the following information about your use of our Website and our online Services through cookies, web beacons, log files and other technologies (subject to your consent where required by applicable law): your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Website or use our Services, your activities on our Website, and the referring URL or the webpage that led you to our Website. Please see the section “Our Use of Cookies and other Tracking Mechanisms” below for more information.

If you express an interest in obtaining the services we offer, by representing or in association/partnership with our trusted partners, we generally require you to provide us with your contact information and other relevant information to perform such services. We may share those information fully or partially to our trusted partners to deliver such services. When you supply us with your contact information online, you will only receive contact from those RPH Group trusted partners regarding matters relating to the services you expressed your interest, such as various consultancy services we offer and/or settlement and/or studying in the country you choose; Our trusted partners whose names, addresses and contact information are reproduced below.

Trusted Partners	Contact Information
ApplyBoard Inc (“ApplyBoard”)	101 Frederick St, Kitchener, ON N2H 6R3 dpo@applyboard.com https://www.applyboard.com/privacy-policy
Royal Bank of Canada (“RBC”)	Office of the RBC Chief Privacy Officer PO Box 7500, Station A Toronto, ON M5W 1P9 dpo@rbc.com (for UK and European Residents/Citizens) https://www.rbc.com/privacysecurity/ca/
Accu-Search Registries Inc.	215 Edmonton City Centre, East 10205 – 101 Street NW Edmonton, AB T5J 2Y9
James & James Chartered Accountants	HB 48, 2^nd Cross Road, Panampilly Nagar, Kochi-682 036 info@jjglobal.in

If you choose to sign up for our consultancy services newsletter/updates/offers, we require you to provide your email address. Our newsletter/updates/offers are distributed electronically and delivered directly to your inbox at least twice per month. It may also be accessed directly on our website, blogs, social medias or portals, which is part of the RPH Group;
If you answer and submit one or more of the Eligibility Questionnaires and/or the various score calculators on our websites/landing pages/portals, depending on the specific questionnaire(s), we generally require you to provide us with the following personal information, including: your name, email address, phone number, age, nationality, country of residence, immigration status, relationship and marital status, parental status, financial status, employment history, business ownership, and education background, religious or philosophical beliefs, trade union membership, generic or biometric data, health information, travel documents. You may also choose to submit your resume or other personal information pertinent to the evaluation of your eligibility for our consultancy services. Thereafter, we may send follow-up emails to the email address provided by you regarding your consultancy services inquiry, unless you have unsubscribed or requested to no longer receive these emails. Your personal information will be shared with RPH group and our third-party service providers acting as data processors and will be used for the sole purpose of providing the Services you request and will not be shared or used by us for any other purposes.
If you create an account to use one or more of the following online services, including our Websites, Client Portals, Softwares and our partners’ Websites, Portals or Software, we may ask you to provide a username, your email address, and a password or sign in with Facebook, Apple, Microsoft and Google;
You do not have to create an account to visit and browse certain features of our Websites, such as to browse various services and packages, read other content portions of the Websites, or determine your eligibility for certain services. If our educational or career clients choose to use our Websites/Portals to discover programs you are eligible to apply for, we collect personal data such as your nationality, country of education, highest education, grading scheme, grade average, English/French exam score(s) and the disciplines or programs that you are interested in pursuing. RPH Group uses this information to create a list of programs and schools to which you are eligible to apply.
You can post information (e.g., questions, comments and opinions) through RPH Groups services or on social media platforms, such as Facebook, LinkedIn, WhatsApp, Signal or Instagram, as well as send us direct messages via these platforms. Please be advised that any personal data that you voluntarily post to any public forum will be available to other individuals and you should exercise caution when posting any personal data. Content you post on sites owned by third parties (such as social media platforms) is subject to the privacy policies of those third parties.
You will have the ability to access our services and provide voluntary personal data so we can register you as an individual taking our services. As a certificate of completion may be issued, we will keep a record of you having registered and/or completed the service offering.
If you use and interact with our websites, we automatically collect log files and other information about your device and your usage of our websites through cookies, web beacons, or similar technologies, such as IP addresses or other identifiers, which may qualify as personal information (please view the “Device and usage data” section below);
In order to apply to an educational or immigration program, you (or the partner or counsellor or agent acting as your representatives) are required to create your profile with us. The personal data we collect in your profile helps us match you with programs that fit your preferences and qualifications. This information may also be required by the institutions/professionals/government bodies for the purposes of processing your application. This information may include your first and last name, email address, gender, date of birth, home and mailing address, passport details, marital status, emergency contact information, English or French language test score(s), educational preferences (such as preferred study destination and educational fields of interest), education history, volunteer experience, and other educational information. In some circumstances, programs may also require us to collect your personal health information, including COVID-19 vaccination status, as part of your application process. Throughout the application process, you have the option to provide additional information. This information is not required to process your application but is recommended to enhance the success of your application. We may use your profile information and other information about your use of the Websites/Portals (such as search queries or other links you click on) to provide you with tailored service recommendations.
We may create and provide you with a alternative email accounts to facilitate your communications with certain institutions. Alternative email accounts are only used for applying to programs you choose, through RPH Group and our associated professionals/consultants/partners. RPH Group monitors the incoming and outgoing emails from alternative email accounts and may collect information from those emails so that you do not miss any important information regarding your application. You can disable the functionality of this email account by contacting us as set out below.
We offer our clients the option of processing their visas through RPH Group’s associated consultants who are registered and authorized to do visa processing in respective countries. If you choose to use this service, we may collect personal data for the purposes of processing your visa application (if necessary), including passport details and information included on a visa application form.
We provide online support services powered by third parties (e.g., Microsoft, HubSpot,) on our Websites/Portals/Social medias or when you contact us, including a live chat functionality. These support services enable us, and the service providers we work with, to communicate instantly with you and to provide additional information or answer any questions. Your information is collected with the aim of operating the online support services and analyzing the use of those services. It may include your first and last name, phone number, email address, IP address, and other data communicated while using the support services. In addition, the support services may collect browsing and usage data in the pages where they are installed, even if you do not actively use them. Live chat conversations may also be logged for quality assurance and training purposes.
If you would like to retain our services and use our Payment Options, we may ask you to provide your name, email address, billing address, phone number and payment information. in order to assist us in completing your transaction, processing your payment, communicating with you about your purchase and arranging physical/electronic delivery of your product and services. We do not store credit card information entered through an e-commerce platform; rather, that e-commerce platform, who is PCI DSS compliant, facilitates secure payment processing. By using our services, you are subject to the third party or e-commerce platform’s Terms of Service and Privacy Policy. Information that a user submits to purchase our services will be transmitted to and shared with third parties that may be located in the countries outside the country in which the user resides, in order to provide services to the user, including but not limited to transaction processing and fraud prevention.
RPH Group uses, with your consent, third party PCI certified payment service providers including but not limited to Western Union, Flywire or Stripe. When you directly make a payment using these payment service providers, you are subject to their privacy policies. They are independent of RPH Group and RPH Group is not responsible for their privacy practices.
When you contact us with a comment, question, or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service, products, service offerings, events, and promotions.
We may obtain personal data about you through your legal representative, or partner(s) or counsellor(s) or Business Development executive(s) who you are working with and who are using our services to process your application to the services we or our associates offer. Occasionally, RPH Group will obtain information about you from third parties, such as mailing list providers and third-party service providers. Third-party providers are responsible for obtaining consent to provide personal data to us.
In connection with a job application or related inquiry regarding potential employment with RPH Group, you may provide us with certain personal data about yourself (such as that contained in a resume, cover letter, or similar employment and education-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.
In connection with applying to become a potential business development executive with RPH Group, you may provide us with certain personal data such as your first name, last name, address, email address, personal data about your education and employment background, Government issued IDs and banking data. We use this information for the purpose of processing and responding to your application to become an RPH Group business development executive and for paying you as needed using third party payment processors.
In connection with applying to become a potential Associates/Associated Service Provider/Counsellor with RPH Group, you may provide us with certain personal data such as your first name, last name, address, email address, personal data about your education and employment background, Government issued IDs and banking data. We use this information for the purpose of processing and responding to your application to become an RPH Group Counsellor/ associate/ associate service provider and for paying you as needed using third party payment processors.

3.2. Personal information of children

You must be at least 18 years old to create any account with the RPH GROUP and to sign up for our newsletter/updates/offers. We do not knowingly collect any personal information from children under the age of 18. Those under the age of 18 should not use the RPH GROUP websites or provide us with any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and if you have reasons to believe that a child under the age of 18 has provided personal information to us, please email us at privacy@rphconsultancy.com

3.3. Device and usage data

a) Log files

We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain personal information, from your computer or mobile device as you navigate our websites or interact with the emails, we have sent to you.

As is true of most websites, we gather certain information automatically via log files. This collected information may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages, and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage.

This information is used to comply with data contracts, treaties, national laws, and regulations, analyze overall trends to help us provide and improve our websites, and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the RPH GROUP’s security features.

b) Cookies, web beacons, and other tracking technologies

We use cookies and similar technologies such as web beacons, tags, and Javascript alone or in conjunction with cookies to compile information about usage of our websites and interaction with emails from us. We will always ask for your consent prior to placing a cookie on your computer or device. When you visit our websites, our servers or an authorized third party may place a cookie on your browser, which can collect information, including personal information, about your online activities over time and across different sites. Cookies help us ensure our websites are not misused by bots and prevent account login information sharing.

Strictly necessary cookies.	These are cookies that are required for the operation of our Websites/Portals. They include, for example, cookies that enable users to log into secure areas of our Websites/Portals.
Analytical/performance cookies.	These types of cookies allow us to recognize, count the number of visitors, and see how visitors move around our Websites when they are using it. This assists us to improve the way in which our Websites works, for example, by ensuring that you can find what you are looking for easily.
Functionality cookies.	These cookies are used to recognize you when you return to our Websites. They enable the personalization of content, recognition of users, and also remember your user preferences (for example, your choice of language or region).
Targeting cookies.	These cookies record your visit to our Websites/Portals, the individual pages visited, and the links followed. If the cookie is set by a third party (for example, an advertising network) which also monitors traffic on other websites, this type of cookie may also be used to track your movements across different websites and to create profiles of your general online behavior. Information collected by tracking cookies is commonly used to target online advertising.

We may use both session-based and persistent cookies. Session cookies exist only during one session and disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer or device. You can control the use of cookies at the individual browser level but, if you choose to disable cookies, it may limit your use of certain features or functions on our websites or services. Should you wish to opt-out from any given type of cookie tracking for which you have previously opted-in, including Google Analytics, please use the specific opt-out mechanism as indicated further below in “Opt-in and Do Not Track Feature”.
There are several ways for you to manage cookies and other tracking technologies. Through your browser settings, you can accept or decline cookies or set your browser to prompt you before accepting a cookie from the websites you visit. You should be aware that you may not be able to use all our interactive features if you set your browser to disable cookies entirely.
If you use different computers in different locations, you will need to ensure that each browser is adjusted to suit your preferences. You can delete or disable any cookies that have been installed in the cookie folder of your browser. The various browsers provide different procedures to manage your settings. Click on any of the browser links below for instructions.

Microsoft Windows Explorer

Google Chrome

Mozilla Firefox

Apple Safari

If you are not using any of the above-listed browsers, then you should select “cookies” in the “Help” function for information on where to find your cookie folder.

You should also be aware that disabling cookies does not disable other types of analytics products which we may use to collect generic information about how you and other visitors use our website.

We may also store your user information and Website preferences locally within your web browser via HTML5. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Websites or Services to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Websites and Services usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Cookies Overview

TYPE AND PURPOSE

VENDOR

OPT-OUT

Strictly Necessary Cookies:

These session cookies are used to provide the basic functionality of the site, including login, page, and content authorization.

OneTrust:

Used for cookie compliance purposes to maintain the cookie preference settings of visitors.

OneTrust:

OneTrust Privacy Policy OneTrust Terms of Use

OPT-OUT NO:

The site will not function without these cookies. They cannot be OPT- OUT.

Analytics:

Used to identify and count the number of site visitors and analyze their movements around the Site (including number of page views, number of visitors, and time spent on each page). This helps us to improve the way our sites work, for example by making sure you can easily find what you need and monitor the performance of our application in order to improve it.

Google Analytics:

Google Analytics Privacy Policy

Information on their expiration is available in their policy.

Google Analytics Terms of service

Mixpanel:

Mixpanel Privacy Policy

Mixpanel Terms of Service

OPT-OUT YES:

Adjustments to your browser settings as explained in section above under the “DISABLING/ENABLING COOKIES VIA YOUR BROWSER” section.

Providers often offer direct opt- out tools.

Google Analytics Opt-Out

Add-On’s for your browser

Functionality / Cookie Management: 

Used to control the Cookie OPT-OUT functionality on the site

Google Tag Manager:

Google Tag Manager Privacy Policy

Google Tag Manager Terms of service

OPT-OUT NO:

This functionality is required to manage other cookies on the system. Without it there cannot be an OPT- OUT option on the site.

Functionality:

Elegant Themes – Divi Plug In:

Theme tool used by the RPH Group’s marketing team to build out the marketing content on the website.

Elegant Themes Privacy Policy

Elegant Themes Terms of Service

OPT-OUT: YES

HelloBar:

Used to maintain the user’s session – Show promotion and information related to new features and website issues to relevant visitors as a website pop-up.

HelloBar Privacy Policy HelloBar Terms of Service

Adjustments to your browser settings as explained in section above under the “DISABLING/ENABLING COOKIES VIA YOUR BROWSER” section. Providers often offer direct opt- out tools.

HubSpot:

Used to maintain the user’s session – Targeted Marketing Automation and enabling user support.

Hubspot Privacy Policy

Hubspot Terms of Service

Hubspot Cookie Policy

Advertising/Targeting:

These cookies are specifically designed to gather information from the browser on your device to display advertisements to you based on relevant topics that interest you.

Mixpanel:
Mixpanel Privacy Policy
Mixpanel Terms of Service

Facebook:
Facebook Privacy Policy
Facebook Terms of Service

OPT-OUT: YES

Adjustments to your browser settings as explained in section above under the “DISABLING/ENABLING COOKIES VIA YOUR BROWSER” section. Providers often offer direct opt- out tools.

We also use web beacons on our websites. For example, we may place web beacons in notification emails that notify us when you click on a link in the email that directs you to one of our websites. Such tracking technologies are used to operate and improve our websites and email communications and to track the clicking of links or opening of emails. All cookies placed by RPH Group expire after 12 months.

c) Opt-in and Do Not Track Features

You may opt-in to collection of device and usage data by managing your cookies at the individual browser level or use the opt-out tool here. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the websites.

While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies, or regulators. Like most other companies, our websites are not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted. Click here for more information on “Do Not Track.”

d) Social Media Features

Our websites may use social media features, such as the Facebook “like” button, the Twitter “Tweet” button, and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted directly on our website. To the extent the Social Media Features are hosted by the respective social media networks, the latter may receive information that you have visited our website from your IP address. If you are logged into your social media account, it is possible that the respective social media network can link your visit of our websites with your social media profile.

Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.

e) Online behavioral advertising and use of advertisers

We partner with a third-party ad network to either display advertising on our website or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other websites to provide you targeted advertising based upon your interests, which is called online behavioural advertising. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using the specific opt-out mechanism as indicated above in “Opt-in and Do Not Track Feature”. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

f) Links to other websites

Our Website may contain links to other websites that RPH Group does not own or operate, including the websites of third-party partners. Also, links to our website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites may have separate and independent privacy statements, notices, and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

· g) Third-Party Analytics

RPH Group uses the web analytics services from Google Analytics, HubSpot, Hellobar, Mixpanel and Freshpaint to collect standard internet log information. Tools such as these may use cookies to help us analyze how visitors use the Websites. For example, with Google Analytics, the information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by a Google server. Google uses this information for the purpose of evaluating your use of the Website, compiling reports on Website activity for Website operators, and providing Website operators with other services relating to Website activity and internet usage. You can prevent the storage of data relating to your use of the Website and created via the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links: https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/topic/2919631

RPH Group also uses Google OCR, “Optical Character Recognition” service to convert your uploaded images into text for data import into your selected RPH Group applications for the sole purpose of eliminating processing errors in your selected program application while decreasing processing times.

· h) Third-Party Ad Networks

We use third parties, such as network advertisers and other marketing agents, to display advertisements on our websites/landing pages/blogs, to assist us in displaying advertisements on third party websites, and to evaluate the success of our advertising campaigns. Network advertisers are third parties that display advertisements based on your visits to our website and unrelated third- party websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your use of our Website and our Services, as well as aggregate or non-personally identifiable information about visitors to our Websites and users of our Services.

For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioral ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

We may also use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt out of the use of your information for such purposes, please contact us at privacy@rphconsultancy.com.

3.4. Purposes for which we process personal information and the legal basis on which we rely

We collect and process your personal information for the purposes and on the legal basis identified below:

Providing our services and performing contracts: We base the processing of your personal information on our legitimate interest to operate and administer our websites and tools, and on the performance of any contract with you to provide you with content you access and service you request according to any applicable terms of Service;
Managing user registrations: We will process your personal information by managing your user account for the purpose of performing the contract with you according to any applicable terms of service, and relevant national laws and regulations;
Handling contacts and user support requests: If you fill out a “Contact Us” and/or one or more Eligibility Questionnaires, request client support, or if you contact us by other means, we will process your personal information to the extent it is necessary for the purpose of our legitimate interests to fulfill your request and communicate with you;
Developing and improving our websites and other platforms: We will process your personal information to analyze trends and track your usage of our websites and interactions with emails to the extent this is necessary for our legitimate interests to develop and improve our websites/other platforms and to provide our users with more relevant content;
Sending communications: We will process your personal information to send you the latest updates about us, including information about our service, to the extent you have provided your prior separate consent (please also view the “Your access to and control over your personal information” section below).
Complying with legal obligations: We will process your personal information when co-operating with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal information to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of data hosted on our site, our data, our websites, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with judicial proceedings, court order, or legal process, and/or to respond to lawful requests.

Where we need to collect and process personal information by law, or under a contract we have entered with you and you fail to provide that required personal information when requested, we may not be able to perform the contract.

Where your personal information is anonymized or de-identified, we do not require a legal basis to use it as the information will no longer constitute personal information under the applicable data protection law. Our use of anonymized or de-identified data is not subject to this Policy.

3.5. How and why, we share your Personal Information

With whom we share your personal data	Reason
Educational Institutions	We share the information in your application with the schools that you are applying to (either directly or through a third party on your behalf, within Canada or abroad). Once RPH Group has provided your information to these institutions or third parties for your application for admittance, RPH Group does not have any control over the use of such information by these institutions or third parties and recommends that you contact them directly if you have any questions about the manner in which your personal data is treated.
Service Providers	We may transfer (or otherwise make available) your personal data to third parties who provide services on our behalf. For example, we may use service providers such as cloud providers to send our emails, host the Website and data (including cloud providers) and operate certain of its features. Other service providers may assist us with the provision of the services, help us verify your identity, prevent, detect, and protect against fraudulent activity or abuse of our services, conduct internal research and analytical assessments, process your transactions, maintain your account(s) and provide you with customer care services. These service providers include internet service providers, data and cyber security services, banks, financial institutions, payment processors, financial services providers, remote access services, service providers that help us verify your identity and help us comply with our legal and regulatory obligations, and our business, legal, tax, financial and other advisors, on a confidential basis. Your personal data may be maintained and processed by third party service providers in the US or other jurisdictions. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal data for their own marketing or other purposes.
Parties to and those involved in a business transaction with RPH Group	We may transfer any information we have about you as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of RPH Group or as part of a corporate reorganization or other change in corporate control.
Researchers	With your consent, RPH Group uses your data internally for research and development to improve our existing products and services and/or create new features to serve you better. RPH Group also uses non-personal data (“Metadata”) for this same purpose. With your consent, we may share your personal data with third parties involved in research and development to improve our existing products and services and/or create new features to serve you better. Such third parties may include our associates, educational institutions, academics, and others in similar fields.
Lawyers, courts, and law enforcement	RPH Group and our Canadian, US and other service providers may provide your personal data in response to a search warrant or other legally valid inquiry or order, or to an organization in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, US or other law. We may also disclose personal data where necessary for the establishment, exercise, or defense of legal claims, to detect, suppress or prevent fraud, and to investigate or prevent actual or suspected loss or harm to persons or property. Where you have engaged a client development partner or recruitment partner or counsellor to avail services from RPH Group, we may be required for legal, regulatory and/or compliance purposes to contact you directly to confirm certain information provided in connection with your application process.
Associated Partners/Professionals	We may transfer (or otherwise make available) your personal data to our associated Partners and professionals who provide services on our behalf. Our service providers are given the information they need to perform their designated functions.

4. THIRD PARTIES AND INTERNATIONAL TRANSFER

All information you provide to us is stored in the servers of our cloud service providers. We take reasonable steps to ensure our service providers adhere to the security standards we apply to your information. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or portals, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Your personal information may be collected, transferred to, and stored by us in Canada or USA. Some of our service providers are also located outside of this region. While we use appropriate safeguards to keep your information secure, the laws in other places may differ from those in Canada and authorities in those jurisdictions may access your information in accordance with their local laws. We will use reasonable means to ensure that personal information is protected regardless of where your personal information may be located. Therefore, your personal information may be processed outside the EEA, and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection in the EEA. In this event, we will ensure that such recipient offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

We may transfer personal information to non-affiliated third parties in providing the services, such as IT and system administration and hosting, research and analytics, marketing, account management, technical operations, credit card processing and email service providers to send out emails on our behalf, pursuant to agreements that prohibit the third parties from using or disclosing the personal information other than for the purpose of processing and which impose security safeguards appropriate to the sensitivity of the information.

We do not sell or rent your personal information to non-affiliated third parties except as permitted by law or as outlined within this Policy. However, in the event of a sale of all or substantially all of our business or another similar transaction, we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this Policy.

Our contracted service providers whose names, addresses and contact information are reproduced below. We reserve the right to disclose your personal information as required by law, and as necessary to protect the property, interests and rights of the RPH GROUP.

Service Providers	Contact Information
Hostinger (Cloud hosting)	Hostinger Hostinger International Ltd. 61 Lordou Viranos Street, 6023 gdpr@hostinger.com https://www.hostinger.com/privacy-policy
Microsoft (Business Softwares)	Microsoft Corporation Microsoft Privacy, Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052ho https://www.microsoft.com/en-ca/concern/privacy https://privacy.microsoft.com/en-ca/privacystatement
Google (Business Suite)	Google LLC Mountain View 1600 Amphitheatre Parkway – 32465 data-access-requests@google.com https://policies.google.com/privacy
HoneyBook (Payment Processing)	Honeybook.com 539 Bryant St, San Francisco California – 94107 concierge@honeybook.com https://www.honeybook.com/terms/privacy
Square (Payment processing)	Block Inc / Squareup Pte. Ltd. 1455 Market Street, Suite 600 San Fransisco, CA 94103, USA privacy@squareup.com https://squareup.com/ca/en/legal/general/privacy
Moneris (Payment processing)	Moneris 3300 Bloor Street West, Toronto, ON Canada M8X 2X2 privacyofficer@moneris.com https://www.moneris.com/en/legal/privacy-notice
Google Analytics (Website analytics)	Google LLC 1600 Amphitheatre Parkway Mountain View CA 94043, USA data-access-requests@google.com https://policies.google.com/privacy
ActiveCampaign (Email Marketing & Newsletter)	ActiveCampaign 1 North Dearborn Street, 5th floor Chicago, IL 60602 privacy@activecampaign.com https://www.activecampaign.com/legal/privacy-policy
HubSpot (Customer Relationship Management)	HubSpot Inc 25 First Street, 2^nd Floor Cambridge, MA 02141, USA https://preferences.hubspot.com/privacy hhttps://legal.hubspot.com/privacy-policy
Xero (Accounting and Invoicing)	Logiciels Baromaitre inc. 250 University Ave, Suite 400, Toronto On, Canada M5H 3E5 https://central.xero.com/s/article/Privacy-at-Xero https://www.xero.com/ca/legal/privacy/
Intuit QuickBooks (Accounting and Invoicing)	Intuit Canada ULC 5100 Spectrum Way Mississauga, ON L4W 5S2 privacyofficer@intuit.com https://www.intuit.com/ca/legal/privacy-policy/

In individual cases, we may also share personal information with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in countries in which we operate, who provide consultancy, banking, legal, insurance, and accounting services.

Any personal information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and/or used by others who visit these forums, depending on your account settings.

5. RETENTION OF PERSONAL INFORMATION

We will keep your personal information only as long as it is reasonably necessary for the time consistent with the original purpose of collection, or such longer period as may be required by applicable law. We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of your personal information, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means.

After expiry of the retention periods, your personal information will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will inform you and put in place appropriate measures to prevent any further use of the data.

Typically, personal data is maintained during the time you are availing services of RPH Group, or our associates. for up to a year following our termination of service. We may retain certain data as necessary for: legitimate business purposes, such as auditing, account recovery; if required by applicable federal, state, provincial or other laws; to prevent fraud or future abuse, or by contract with a partner and/or institution. All retained personal data is treated in accordance with this Policy.

If you request that your personal data, be removed from our databases and/or systems, it may not be possible to completely delete all your personal data due to technological and legal constraints. However, we will take such steps as are reasonable to securely destroy the information or to ensure that the information is de-identified and/or anonymized as necessary. Should you request additional services from RPH Group, which are subject to this Policy, you will be authorizing the extension of the data collection and/or processing purpose as a result.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Websites and other platforms; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. RPH Group promptly evaluates and responds to incidents that create suspicion of or indicate unauthorized access to or handling of personal data. If we become aware and determine that an incident involving personal data qualifies as a security breach leading to the unauthorized access, use, modification, or disclosure of personal data in our custody and control, we will notify you of such breach without undue delay. We will provide timely information relating to the breach as it becomes known or reasonably available to us and to the extent permitted by law.

6. YOUR ACCESS TO AND CONTROL OVER YOUR PERSONAL INFORMATION

You may exercise any of the rights described below by sending an email to privacy@rphconsultancy.com. Please note that we may ask you to verify your identity before taking further action on your request. We will process your request within 30 days of receipt, unless it is particularly complicated or you have made several requests, in which case we may extend this by two (2) months. We will let you know if we are going to take longer than one (1) month in dealing with your request. If we have a lot of information about you, we might request what exactly you want to receive. This will help us action your request more quickly.

6.1. Managing your information

You may access and update some of your information by accessing your account with the RPH GROUP or any of its affiliates, as applicable. You are responsible for keeping your personal information up to date. You can also ask us to correct inaccurate or incomplete personal information concerning you that you cannot update yourself within your account.

6.2. Access to your information

You have the right to request information about the personal information we hold on you at any time. You can contact us at privacy@rphconsultancy.com and we will provide you with your personal information via email. If you require additional copies, we may need to charge a reasonable fee.

6.3. Right to erasure

We keep your personal information for as long as it is necessary for the performance of the contract between you and us, for our legitimate business interests, to comply with our legal obligations and protect our rights. If you no longer want us to use your information to provide you with our latest news or any of our services, you can request that we erase your personal information and close your account(s).

Please note, however, that we may retain some of your personal information as necessary for our legitimate interests, such as fraud detection and enhancing security. We may also retain and use your personal information to the extent necessary to comply with our legal obligations, such as keeping information for tax, legal reporting and auditing obligations, as well as professional obligations. Information you have shared with others (eg. reviews, forum postings) may continue to be publicly visible. Additionally, some copies of your information (eg. log records) may remain in our database but are disassociated from personal identifiers. Residual copies may also be kept in our backup systems. If we have shared your personal information with third-party service providers, we will let them know about the erasure where possible.

Please note that these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it means that we are not able to meet our contractual obligations and provide our Services to you. We will keep you informed as to the actions that we can take when you make your request.

6.4. Right to object to direct marketing

We want to communicate with you only if you want to hear from us. If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. If you have already given your consent but you prefer not to receive promotional information from us, you may unsubscribe from our consultancy services Newsletter/Updates/Offers email services by using the unsubscribe link situated at the bottom of any promotional message you receive from us, or email us at privacy@rphconsultancy.com. Please be sure to include the email address you used when you subscribed to our consultancy services emails.

6.5. Restriction of processing

You can ask us to block or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it and we have no legitimate grounds that override yours. Such request alone does not stop us from storing your personal information.

6.6. Right to portability

Whenever we process your personal information, by automated means based on your consent or based on an agreement, you have the right to get a copy of your personal information transferred to you or to another party. This only includes the personal information you have provided to us.

6.7. Automated decision making

You have the right to elect not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”).

At the moment, certain Eligibility Questionnaires and Score calculators on our websites use Automated Decision-Making. The Eligibility Questionnaires use results of Automated Decision-Making to help us determine your eligibility for Our consultancy services based on the information you provide. The Express Entry CRS Calculator uses Automated Decision-Making to assess your score based on the CRS points system used by Immigration, Refugees and Citizenship Canada (IRCC), and the information you provide. If you elect not to be subject to Automated Decision Making, please refrain from using the Eligibility Questionnaires and the Express Entry CRS Calculator.

6.8. Consent withdrawal

To the extent we base the collection, processing, and sharing of your personal information on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

6.9. Right to non-discrimination

If you are a Californian resident, we will not discriminate against you for exercising any of your rights under the California Consumer Privacy Act (the “CCPA“), including your right of access and right to erasure. Unless permitted by the CCPA, we will not deny you services, charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties, provide you a different level or quality of services, or suggest that you may receive a different price or rate for services or a different level or quality of services.

6.10. Authorized agent

If you are a Californian resident, you may use an authorized agent to exercise certain privacy-related requests and rights on your behalf. The authorized agent’s exercise or request on your behalf sent by mail shall include a power of attorney or a notarized statement properly signed by you appointing such authorized agent for such purpose. If your authorized agent submits the exercise or request online, a copy of the power of attorney or the original notarized statement shall be sent to us by mail.

. 6.11. Questions or complaints

If you have any queries or to make any complaint in relation to this Policy and RPH Group’s privacy practices, you may write to our data protection officer at privacy@rphconsultancy.com or at the following address:

Data Protection Officer

Royal Priesthood Group
8934 133Ave NW
Edmonton, Canada
Phone: 1-780 720 3282

If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.

7. Personal Information Security

We take reasonable precautions to ensure the protection of personal information, collected, used or disclosed by us using appropriate physical, organizational and technological measures. We use industry-standard encryption technologies to receive sensitive data submitted by you on our platforms.

In case of a personal data breach that is likely to result in high risk to your rights and freedoms, we will notify you and the proper authority within 72 hours of becoming aware of the breach and without undue delay.

While we follow generally accepted standards to protect personal information, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us using the contact information in the “Questions or complaints” section above.

8. Changes to Our Privacy Policy

This Policy may change from time to time. Any changes in the future will be posted on our website and, where appropriate, we will notify you by email, or via your “Account” on our portal.

We strongly encourage you to check back frequently to see any updates or changes to our Policy. We will not materially reduce your rights under this Policy without taking steps to bring such changes to your attention.

9. Appendix 1: Additional Terms for EEA and UK Customers

The information below is required pursuant to EEA law regarding privacy and data protection. The terms below apply to our EEA and UK customers and Website visitors, in addition to the terms in the rest of the Policy. For the purposes of the General Data Protection Regulation (“GDPR”), the data controller is RPH Group of 8934 133 Ave Edmonton, Canada T5E 1C2. If you have any questions about this Policy, please contact our Data Protection Officer (DPO) at privacy@rphconsultancy.com

If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to your local supervisory authority.

WHEN DO WE SHARE YOUR PERSONAL DATA?

The table headed “How and Why We Share Your Information” in the main part of the Policy under the heading “WHEN DO WE SHARE YOUR INFORMATION” lists who we may share your information with, which include transfers for reasons of legal compliance and necessity in order to provide you with our Services.

You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside the EEA or the UK, as applicable.

Please note that where data is transferred outside of the EEA, non-EEA countries may not offer the same level of protection for personal data as is available in the EEA. RPH Group will take various measures to ensure that your data is treated securely, which may include, but not be limited to:

assessing the security measures taken at any place your personal data is transferred to;
having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions;
having monitoring, reporting and resolution procedures in place with regard to ongoing security; and
only transferring your data via an appropriate safeguard as described in Article 46 of GDPR, including Standard Contractual Clauses adopted by the European Commission (Article 46.2)

Please contact us at privacy@rphconsultancy.com if you require more detailed information about international transfers of your personal data, and the particular safeguards used.

LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

We process your personal data based on the following legal bases, as recognized by and in compliance with the applicable data protection laws:

the processing is necessary to perform our contract with you (i.e., the Terms and Conditions that apply as applicable with respect to RPH Group Services, for the provision of our Services), or to take steps requested by you before entering into said contract;
you are obliged to provide us with personal data as it is necessary to enter into and perform our contractual agreements. In the event that you do not wish to provide us with your personal data for the purposes outlined above in the “How and why we use your information” section, we will not be able to perform our contractual agreement with you;
the processing is in RPH Group’s or someone else’s legitimate interests, and these interests are not overridden by your interests or rights in the protection of your personal data. This may include processing your data for prevention of fraudulent activity, internal research and analytics assessments, for purposes of communication with you, and informing you about new products and services we are offering or to promote new products and services of other parties which we think may be of interest to you, etc.;
before we process your personal data to pursue our legitimate interests for the purposes outlined above in the “How and why we use your information” section, we determine if such processing is necessary, and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms.
you have given your consent to the processing of your data;
the processing is necessary to meet a legal obligation which applies to RPH Group

Sometimes we process data about you which the law considers falling within special categories (see section “What data do we process about you?” for more details), in which case, we use one of the following grounds:

the processing is necessary for the establishment, exercise or defense of legal claims;
you have freely given your informed, specific consent to the processing; or
the processing is necessary for reasons of substantial public interest, based on applicable law.

If you would like more information about the legal grounds used to process your information, or about the legitimate interests referred to above, please contact us.

In cases where we have asked for, and you have given, your consent to our processing of your personal data, you have the right to withdraw such consent at any time. You can do this by contacting our DPO at privacy@rphconsultancy.com

DO YOU HAVE TO GIVE US YOUR PERSONAL INFORMATION?

In most cases, providing your personal data to us is optional, however, if you do not provide it, you will not be able to use our Services. For example, we need details such as your name, address, and bank account details so that we can make payments to you and receive payments from you. In other cases, you have a choice over whether we collect your personal data, for example, you can turn off cookies on your browser and we will not place any cookies on your device or computer (although in this case you may not be able to use all parts of our websites).

PROFILING AND AUTOMATED DECISION MAKING

We use automated decision making as part of the RPH Group Services. We use these tools as a measure of fraud prevention and for purposes of security and risk assessment relating to the performance of the RPH Group Services:

Automated tools incorporated in our process of approval of your application: based on the information you provided, the tool may advise if additional information is required for the purpose of approval of your application.
Automated tools incorporated in our process of approval of certain services of: such tools may advise if additional information is required for the purpose of eligibility or determine eligibility.
Automated tools incorporated in our process of performing certain services of: such tools may advise if additional information is required for the purpose of performing/providing such services.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

RPH Group will only retain your personal data while it is needed to fulfill the intended purpose for which it was collected or as otherwise permitted or required by law or contract (which may extend beyond the termination of our relationship with you).

Typically, personal data is maintained during the time you are engaged with the services we offer, or for up to a year following our termination/completion of the services offered you. We may retain certain data as necessary for:

legitimate business purposes, such as auditing, account recovery;
if required by applicable federal, state, provincial or other laws;
to prevent fraud or future abuse, or
by contract with a partner and/or institution.

All retained personal data is treated in accordance with this Policy.

Should you request additional services from RPH Group which are subject to this Policy, you will be authorizing the extension of the data collection and/or processing purpose as a result.

Document(s) will be retained for as long as they are needed for the intended purpose, or as required by law or contract (which may extend beyond the termination of our relationship with you).

The entity, client or partner which has uploaded the document(s) may request premature deletion of uploaded files. This is most likely to occur in the case where a content correction or update is required.

YOUR RIGHTS UNDER GDPR

You have several rights in relation to your personal data which are described in more detail below. You can exercise your rights at any time by contacting us at privacy@rphconsultancy.com.

Accessing your data

You can ask us to:

Confirm whether we are processing your personal data.
Give you a copy of that personal data.
Provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it outside of the EEA and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we carry out any automated decision making or profiling. We aim to give you all this information in this Policy, although if anything is unclear, please contact our Data Protection Officer at privacy@rphconsultancy.com

You do not have to pay a fee for a copy of your personal data unless your request is unfounded, repetitive, or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.

Correcting your personal data

You can ask us to correct any personal data which is inaccurate or incomplete (in most cases you will be able to make these changes yourself by logging into your portal). This is free of charge.

If we have shared the personal data with anyone else, we will let them know about the correction wherever possible. If we cannot action a request to correct your personal data, we will let you know and explain why this is.

Erasing your personal data

This right is sometimes referred to as “the right to be forgotten”. This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.

You can ask for your personal data to be erased where:

it is no longer necessary for the purpose for which it was originally collected or processed;
we are processing your personal data based on your consent, and you withdraw that consent;
you object to the processing of your personal data, and we do not have an overriding legitimate interest for continuing;
it has been unlawfully processed;
it must be erased to comply with a legal obligation;
it was processed to offer information society services to a child.

There are some exceptions to this right. If one of these applies, we do not have to delete the personal data.

If we have shared your personal data with third parties, we will let them know about the erasure of your data unless this is impossible or would involve disproportionate effort.

Please note, in connection with such requests, that personal data may be either deleted or retained in an aggregated manner without being linked to any identifiers or personal data, depending on technical commercial capability.

Restricting the processing of your personal data

You can ask us to restrict the processing of your personal data in some circumstances, free of charge. This is not an absolute right. If processing is restricted, we can store the personal data and retain enough information to make sure the restriction is respected unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or for reasons of important public interest, but we cannot further process your personal data.

You can restrict the processing of your personal data in the following cases:

if you contest the accuracy of your personal data, we will restrict processing until we have made sure the personal data is accurate;
if you object to our processing pending the verification of whether or not our legitimate interests override your interests, rights and freedoms or in connection with legal proceedings;
if the processing is unlawful but you do not want us to erase your personal data;
if we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort. We will let you know if we decide to lift a restriction on processing your personal data.

Objecting to the processing of your personal data

You have a right to object to the processing of your personal data at any time. This request will be free of charge. It is not an absolute right, but you can object to our processing of your personal data where it is:

based on the legitimate interest ground; or
for the purposes of scientific/historical research and statistics.

We will stop processing your personal data unless we have compelling legitimate grounds for the processing which override your interests and rights, or unless we are processing the personal data for the establishment, exercise or defense of legal claims.

You can require us to stop using your personal data for direct marketing purposes. We will stop as soon as we receive your request, however we may not be able to implement this for any direct marketing campaigns which are already in progress. There are no exemptions or reasons for us to refuse.

Data Portability

This allows you to obtain and reuse your personal data for your own purposes across different services. It applies where the following conditions are met:

you provided the personal data to us yourself;
we are processing the personal data either based on your consent or because it is necessary for the performance of a contract; and
the processing is carried out by automated means.

We will provide your personal data free of charge in a structured, commonly used and machine-readable form.

Automated decision making and profiling

You have the right not to be subject to a decision which is based solely on automated processing, and which produces a legal (or similarly significant) effect on you.

You have the right to:

request human intervention;
express your point of view;
ask for the decision to be explained; and
challenge the decision.

These rights are not absolute. We may not be able to comply with this request if the processing of personal data is:

necessary for us to enter into or perform a contract with you;
authorized by law (eg. for fraud prevention) and which also lays down suitable measures to safeguard your right, freedoms, and legitimate interests; or
based on your explicit consent.

Dealing with requests to exercise your rights

We will respond to your request without undue delay at the latest within one (1) month of receiving your request unless it is particularly complicated or you have made several requests, in which case we may extend this by two (2) months. We will let you know if we are going to take longer than one (1) month in dealing with your request. If we have a lot of information about you, we might ask you if you can tell us what exactly you want to receive. This will help us action your request more quickly.

For the purpose of complying with your requests to exercise the rights listed above, we shall perform the necessary internal processes to identify you.

10. Appendix 2: Additional Terms for State of California Customers

The information below is required pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). The terms below apply to residents in the State of California in addition to the terms in the rest of the Policy.

CCPA REQUESTS

Under the CCPA, the State of California residents are provided with specific rights regarding the collection and storage of their personal data.

You or your authorized agent may apply to us with requests as detailed below by contacting us by phone: +1 (780) 720-3282 or via email to privacy@rphconsultancy.com. We do not discriminate against any individual based on the exercise of his/her privacy rights.

CCPA INFORMATION REQUEST RIGHTSYou have the right to request that we provide to you the following information about our collection and use of your personal data over the preceding twelve (12) months. Once your verifiable consumer request has been confirmed through our review of the information you provide in your request, we will disclose to you:

The categories of personal data we have collected about you.
The categories of sources for the personal data we have collected about you (e.g., use of
cookies, third party, etc.).
Our business or commercial purpose for collecting that personal data.
The categories of third parties with whom we share or have shared that personal data.
The specific pieces of personal data we collected about you (also called a data
portability request).
We do not sell your personal data. In addition, if we have not disclosed your personal data for a business purpose, we will disclose this fact to you. If we have disclosed your personal data for a business purpose, including direct marketing, we will provide you with a listing that identifies the personal data categories that each category of recipient obtained.

CCPA Deletion Request Rights

You have the right to request that we delete any of the personal data collected from you and retained, subject to certain exceptions and your verification. Your request to delete the personal data collected may be denied if it is necessary for us to retain your information under one or more exceptions listed in the CCPA.

WE DO NOT SELL YOUR DATA. We do not sell personal data collected about you to third parties. We may share your information with our service providers or as instructed by you from time to time for the purpose of providing you the services and as detailed above under the section titled “WHEN DO WE SHARE YOUR INFORMATION”.

You may contact our Data Privacy Officer by email at privacy@rphconsultancy.com or by mail at the following address:

Royal Priesthood Group
8934 133Ave
Edmonton, Canada T5E 1C2
Phone: 1-780 720 3282