Privacy Policy

In this Privacy Policy, "Alltourage", "we", "us", "our" and "ours" means LWTL Media Inc., and "you" means (and “your” refers to) anyone who provides personal information to us, and their successors, heirs, administrators, executors and assigns (as the case may be).

We have adopted this Alltourage Privacy Policy (the "Privacy Policy") to explain how we will meet our responsibilities with respect to the information you provide to us.  This Privacy Policy applies to both individuals and organizations, from whom we collect personal information.

The principles that form the basis of this Privacy Policy are interrelated and Alltourage adheres to all of the principles as a whole. Each principle should be read in conjunction with the accompanying commentary. As permitted by Personal Information Protection and Electronic Documents Act ("PIPEDA"), the commentary in this Privacy Policy has been drafted to reflect privacy issues specific to Alltourage. We will continue to review this Privacy Policy to make sure that it remains current with exceptions, changing technologies, industry standards and applicable laws.

1. Scope and Application

This Privacy Policy applies to personal information, in any form, collected, used or disclosed by Alltourage in the course of commercial activities.  It will not typically apply to information directly regarding Alltourage's corporate clients.  However, such information may be protected by other Alltourage policies and through contractual arrangements.

This Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Alltourage:

  • information about an individual that is publicly available and is specified by regulation pursuant to PIPEDA;
  • personal information that is not collected, used or disclosed, for commercial purposes;
  • non-personally identifiable information; and
  • the name, title, business address or telephone number of an employee of an organization, where collection, use or disclosure of such information is solely for the purpose of communicating with the person about their employment, business or profession. 

The application of this Privacy Policy is subject to the requirements and provisions of PIPEDA, and any other applicable legislation or regulation. If you reside in British Columbia, Alberta or Québec, then the substantially similar provincial privacy law of your province will apply to our handling of your personal information, rather than PIPEDA.  In that case, reference in this Privacy Policy to PIPEDA shall be deemed to include your province's substantially similar privacy law.


2. Definitions

collection:  The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent:  Voluntary agreement for the collection, use and disclosure of personal information for defined purposes.  The form of consent we seek may vary, depending upon the circumstances and the type of personal information.  In determining the form of consent, we take into account the sensitivity of the personal information and your reasonable expectations.  Consent may be provided directly by you, or by your authorized representative, in accordance with applicable law.

disclosure:  Making personal information available to a third party.

employee:  An employee of, or an independent contractor to, Alltourage.  The inclusion of independent contractors within the definition of "employee" is for convenience of reference only, and should in no manner imply that such independent contractors are our employees within the meaning of employment legislation or are in an employee-employer relationship with us.

personal information:  Information about an identifiable individual, but does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession, such as the individual’s name, position name or title, work address, work telephone number, work fax number or work electronic address.  Where an individual provides their home address to Alltourage as their business contact information, Alltourage considers it to be business contact information, and is therefore not subject to protection as personal information.  Information about corporations is not considered personal information.

third party:  An individual or organization outside of Alltourage.

use:  The treatment, handling, and management of personal information by and within Alltourage or by a third party with the knowledge and approval of Alltourage.


3. How Alltourage Works

Alltourage is a platform that helps employers generate leads for diversity and inclusion candidates for job postings. If you’re an employer, you can sign up for an account and use Alltourage to post job postings and seek candidates through the platform’s network of referrers and candidates. Referrers are people who sign up for accounts and are able to refer job postings to personal acquaintances who they believe may be a good fit for the position. Candidates are personal acquaintances who receive referrals to job postings from referrers, and who can use Alltourage to learn more about specific opportunities. Job seekers are people who use Alltourage to find jobs and who may use Alltourage to apply for those jobs.


4. Accountability for our handing of personal information

Alltourage is responsible for all personal information under its control and has designated the Alltourage Privacy Officer to oversee privacy compliance.  Other individuals within Alltourage may be delegated to act on behalf of our Privacy Officer or to take responsibility for the day to day management of personal information. Alltourage trains and communicates with employees about our privacy practices, including this Privacy Policy. 

As appropriate, Alltourage implements privacy policies and procedures to properly enforce this Privacy Policy, and we use contractual or other means to provide a comparable level of privacy protection while personal information is being processed or used by a third party. 


5.Reasons why we collect, use and disclose personal information

Alltourage collects personal information from you for the following purposes:

  • to verify your identity when you create an account;
  • to notify you about products or services we offer or provide (including job postings, in the case of job seekers or candidates, or potential candidates, in the case of employers);
  • to provide you with information, products, or services that you request from us;
  • to help us coordinate and manage our employees and volunteers;
  • to personalize and improve your use of Alltourage, such as through the use of automated systems to help connect you with job postings; 
  • to improve our products or services, for marketing and newsletters, or customer relationships and experiences;
  • to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal or regulatory requirements;
  • in any other way we may describe when you provide the information; and
  • for any other purpose with your consent, or as required or permitted by law. 

Further reference to “identified purposes” mean the purposes identified in this section of this Privacy Policy.

We will indicate the identified purposes to you, orally, electronically or in writing, at or before the time your personal information is collected.  Persons collecting personal information may explain the identified purposes or refer individuals to a designated person within Alltourage who can explain these identified purposes.


6. Collection of personal information

If you request information, products or services from Alltourage, we will collect your name and contact details, such as your email address, mailing address, telephone number and language preference. In addition:

  • If you have an employer account, we will collect information about the profile of your organization, job postings you may submit to us from time to time and your payment information.
  • If you have a referrer account, we will collect information you provide us about individual candidates with whom you have a personal relationship and who you believe may be a good fit for a job posting, such as their skills and attributes, how long you have known them and the nature of your relationship with them.
  • If you have a job seeker account, including an account which a candidate has chosen to create, we will collect information you provide us about yourself, such as information from social media profiles which you share with us, your education, work, salary and location preference and your resume. If you choose to self-identify any demographic diversity traits, we will associate that information to your profile but will not disclose it to an employer or referrer, without your permission.

If you engage with our social media accounts, we will collect whatever information you provide to us through the applicable platform.

You may also provide us your credit card or other payment information in order to pay for products and services we make available to you, from time to time. We collect this information only for the purposes we indicate to you at the time of collection. 

We collect and retain information about your transaction history when you use our products and services. 

We may also provide you an opportunity to specify certain preferences in respect of our products or services. If you choose to provide such information, we will collect and implement your preferences. This may include information about your profile that you choose, through your account, to make available to employers and referrers who use Alltourage. If you are referred to a job posting, you decide if you want to submit your name to the employer who posted the job. 

Alltourage will only collect personal information that is necessary for the purposes identified in this Privacy Policy or as otherwise agreed to by you.  

In most cases, we collect your personal information directly from you.  Sometimes, however, we use third parties to provide us your personal information:

  • where a referrer has provided information to an employer regarding a candidate’s suitability for a job posting, such as the candidate’s skills and attributes, how long the referrer has known them and the nature of their relationship with them; or
  • where an employer wishes to conduct a background check, information will be collected from third parties in connection with that background check.  More information about background checks is provided in section 8 below.

We collect no personal information about you unless you choose to provide that information to us. We do not use techniques that collect personal information about anyone without their knowledge. We only collect personal information about individuals when they specifically and knowingly provide it to us, for example, when they fill out a registration form on our website or contact us by telephone or email. As a limited exception to this principle, we may collect personal information without your consent:

  • where permitted by PIPEDA and other applicable laws; or
  • from any referrer who has a personal relationship with you, and who refers you to a job posting.  In this case, we will send you details about the job posting and a link to learn more about the job.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. You may contact us for more information regarding the implications of withdrawing consent.


7. Consent for us to contact you about our products and services

The information you provide to Alltourage – such as your name, address, etc. – allows us to inform you about job postings (in the case of job seekers and candidates) or potential candidates who may be a good fit for your organization (in the case of employers), and to notify you of issues, events or special offers which may be of interest to you. 

By signing up for an account, you are giving Alltourage permission to contact you by way of the information you provide. Should you wish not to be contacted by Alltourage, please opt out under Alltourage’s Account Settings and Preferences, or contact support@alltourage.com to do so.


8. Disclosure of personal information

Alltourage will not disclose personal information for purposes other than those purposes for which it was collected, except with your consent or as required or permitted by law. Alltourage may disclose your personal information:

  • to fulfill the identified purposes (for example, by providing your name to an employer, but only if you are a job seeker or candidate who has expressed an interest in a job posting);
  • for the purposes of permitting a third party service provider to conduct a background check. The information disclosed by Alltourage for the purposes of a background check will be limited to the job seeker’s or candidate’s: name, email and phone number. The third party service provider may collect additional information about the job seeker or candidate, depending on the nature of the background check.  Background checks are subject to the third party service provider’s terms and conditions and we recommend you review those terms and conditions before you provide your consent to a background check. Currently, this service is only available to Canadian users;
  • when we have your consent, whether express or implied;
  • to your authorized representatives;
  • if and when we are involved in a corporate reorganization or if we sell or lease all or part of our business; 
  • to meet legal and regulatory requirements; and
  • where required or permitted by law.   

In such circumstances, we will not disclose more information than is required for the purpose for which the information is being disclosed.  We will also, whenever it is reasonable and practicable to do so, enter into privacy agreements with third parties with whom we share personal information.   

Information you submit to your public profile is made available to HR Managers and Employers (as those terms are defined in our Terms of Use).  If you do not want these Alltourage users to view this information, do not submit it to Alltourage.

We will retain personal information only as long as it remains necessary or relevant for the identified purposes or as required or permitted by law.  Where personal information has been used by us to make a decision about you, Alltourage shall retain, for a period of time that is reasonably sufficient to allow for access by you, either the actual information or the rationale for making such decision.  

Only our employees who require access for legitimate reasons or whose duties reasonably so require, are granted access to personal information.  

We maintain reasonable controls, schedules and practices for personal information management retention and destruction.  Personal information that is no longer necessary or relevant for the identified purposes, or is required by law to be retained, is destroyed, erased or made anonymous, as appropriate in the circumstances.

Alltourage may share aggregate information – not personal information – about its employers, referrers, candidates, and job seekers with other parties and related service providers, to help them better understand Alltourage users and their interests.  Such aggregate information is used to give Alltourage demographic data about its users in order to improve our organization and the products and services we provide. 

If you are a referrer, we keep track of the average number of referrals you make through Alltourage, as well as information relative to the average number of candidates who you referred, who apply for job postings through Alltourage.


9. Alltourage website

Our website may use various technologies, from time to time, to:

  • help us customize your experience on our website;
  • track your use of our website for advertising, marketing, or promotional purposes; 
  • help us determine whether you opened an email message from us; or
  • gather information to deliver advertisements about products and services we think may be of interest to you.

This information enables us to:

  • customize the services we offer you, to improve our website;
  • estimate our audience size and usage patterns;
  • store information about your preferences, allowing us to customize our website according to your individual interests, including showing you advertisements that we think will be of interest to you;
  • speed up your searches;
  • recognize you when you return to our website; 
  • show our advertisements on external sites; and
  • assist us in providing a better customer experience by understanding consumer behaviour.

Your choices about how our website collects your information

We strive to provide you with choices regarding the personal information you provide to us. 

You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using opt out tools created by Google Advertising, the Digital Advertising Alliance of Canada or by the Network Advertising Initiative. You may also opt out of our use of Google Analytics by visiting the Google Analytics opt out page. We may have reporting of your aggregate interactions with our ads across the Google Display Network or DoubleClick for Advertisers in conjunction with activity on our website.

You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. 

In addition, we have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this website may not be accessible or may not function properly. 

 

  • Promotional Offers. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by Alltourage to promote our own or third parties’ products or services, you can opt out by contacting Alltourage support: support@alltourage.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. 
  • If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by using the opt out tools created by the Digital Advertising Alliance of Canada, the Network Advertising Initiative or Google Advertising.

10. Accuracy of personal information

We make reasonable efforts to ensure that personal information we collect, use or disclose is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. Please be advised, however, that Alltourage is driven by third party referrals, the accuracy of which we cannot control. In addition, we use algorithms to generate a profile for you, based on information about you that you and referrers have submitted to Alltourage, and that profile is used to help match you to job postings.

If you find any errors in our personal information holdings (including information provided by a third party referral or generated by an algorithm), we should be informed so that we can make the appropriate corrections. We will convey these corrections to any third party that may have been provided inaccurate information. For personal information that remains in dispute, we will make note in our records of your opinion as to accuracy of the relevant personal information. 


11. Security of personal information

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to prevent any unauthorized access, disclosure, copying, use, or modification of personal information. Safeguards include securing physical documents and technological measures by way of secure access and encryption. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions (if applicable) will be encrypted using TLS technology.

Alltourage employees are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent its being lost or destroyed.

We protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the personal information and the purposes for which it is to be used.  

We may engage service providers to assist us with fulfilling the purposes for which personal information has been collected, used and disclosed, and, in some instances, these service providers may be located outside Canada. We only select service providers that protect personal information in a manner that is comparable to the protection we provide under our own privacy policies.  However, personal information may be subject to, and accessed under, the laws of the countries in which our service providers operate.  If you have any questions about our transfer of personal information to our service providers outside Canada, or if you would like to learn more about our privacy policies in that regard, please contact the Alltourage Privacy Officer at the contact information provided below.  


12. Openness concerning our policies and procedures

We are open about the policies, procedures and practices we use to protect your personal information. Information about these policies, procedures and practices will be made available to you either electronically or in writing.


13. Access to your personal information

You may access any personal information that we have concerning you, and which has been collected, used or disclosed for a commercial purpose, by sending a written request to the Alltourage Privacy Officer. Alltourage may advise you in advance if there is a minimal charge to conduct a search of our records and will respond within 30 days, or advise that the request for access is subject to an extension as authorized by PIPEDA. 

To protect your privacy, you may be required to provide sufficient identification, in order to permit us to account for the existence, use and disclosure of certain personal information and to authorize access to such information. Any such information will only be used for this purpose.

We may not be able to provide personal information to you if doing so would violate the privacy of a third party or if certain personal information is subject to legal privilege, contains information proprietary to us or a third party, is too costly to retrieve, or cannot be disclosed for other legal reasons.  If we are unable to provide access to all or part of your personal information, we will explain our reasons for such a decision.

Where you have been provided with access to your personal information, you shall be able to challenge the accuracy and completeness of your personal information and have it amended as appropriate.  

Personal information that is disclosed to third parties by us will be subject to the general laws applicable in the jurisdiction in which the third party conducts business. As a result, and in certain limited situations, we may not be legally permitted to account for certain collections, uses or disclosures of personal information. In most circumstances, however, we shall provide an account of the collection, use and disclosure of personal information and, where reasonably possible, we shall state the source of the personal information. In providing an account of disclosure, we shall provide a list of organizations to which we may have disclosed your personal information when it is not possible to provide an actual list.  

14. Challenging compliance with privacy laws

All questions or concerns regarding our privacy practices should be directed to the Alltourage Privacy Officer.  

We will investigate all complaints concerning compliance with this Privacy Policy and if a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending our privacy policies and procedures.  We will inform you of the outcome of the investigation regarding your complaint.


15. Language

You and Alltourage have requested and agree that this Privacy Policy and all documents related to this Privacy Policy be drawn up in English. Les parties ont demandé que cette convention ainsi que tous les documents que s'y rattachent soient rédigés en anglais.

16. Contact Us

If you have any questions or concerns about this Privacy Policy or about Alltourage's information handling practices, please contact us at:

Attn: Privacy Officer

support@alltourage.com

Please also visit the Office of the Privacy Commissioner of Canada’s website at https://www.priv.gc.ca/en/.