3. Personal Information We Collect

The personal information we collect depends on how you interact with us.
 

Information you provide directly
 

We may collect:

• Your name;

• Email address;

• Telephone number;

• Mailing or billing address;

• Professional title, employer, business name or industry;

• Information submitted through contact, inquiry, application, assessment or booking forms;

• Appointment preferences and scheduling information;

• Communications and correspondence with us;

• Information you choose to share while participating in a session, program or service;

• Professional goals, concerns, experiences and feedback;

• Notes relating to the delivery of our services;

• Course or program participation information;

• Newsletter and marketing preferences;

• Survey responses;

• Testimonial content and consent records;

• Photographs, video or audio content where you have expressly agreed to their collection and use; and

• Any other information you voluntarily provide.

Please do not provide confidential information belonging to your employer, clients or another person unless you are authorized to share it and it is reasonably necessary for our work together.
 

Transaction and payment information
 

When you purchase a service or program, we may receive:

• Your name and billing details;

• The service or program purchased;

• Transaction date and amount;

• Payment status;

• Refund or cancellation information;

• The last four digits or type of payment card, where provided by the payment processor; and

• A payment-provider transaction or reference number.

Payments may be processed by third-party providers such as Stripe, PayPal or a payment service integrated with Wix.
 

We do not receive or store your complete payment-card number. Payment providers process payment-card information under their own terms and privacy policies.
 

Information collected automatically

When you visit our website, we and our authorized technology providers may automatically collect:

• Internet Protocol address or information derived from it;

• Approximate geographic location;

• Browser and device type;

• Operating system;

• Screen resolution and language settings;

• Referring website or source;

• Pages viewed;

• Links or buttons selected;

• Dates, times and duration of visits;

• Website navigation and interaction information;

• Cookie or similar technology identifiers; and

• Information needed to maintain website security and diagnose technical problems.

Google Analytics 4 may use an Internet Protocol address temporarily to derive approximate location and other technical information. Google states that Google Analytics 4 does not log or store individual Internet Protocol addresses.
 

Information received from third parties
 

We may receive limited information from services you use to interact with us, including:

• Wix;

• Scheduling or appointment platforms such as Calendly or Wix Bookings;

• Payment processors such as Stripe and PayPal;

• Email-marketing platforms;

• Video-conferencing platforms;

• Website analytics providers;

• Social-media platforms;

• Referral partners; and

• Other service providers you choose to use.

The information we receive depends on the provider, your settings and the action you take.
 

4. How We Use Personal Information

We may use personal information to:

• Respond to inquiries and requests;

• Determine whether our services are suitable for a prospective client;

• Schedule and administer appointments;

• Enter into and perform contracts;

• Deliver private sessions, programs, courses, digital products and other services;

• Prepare for sessions and provide appropriate follow-up;

• Process payments, refunds and cancellations;

• Maintain client, transaction, accounting and tax records;

• Communicate about bookings, purchases, services and programs;

• Provide customer service and technical support;

• Send newsletters and marketing communications where we have the required consent or other legal authority;

• Record and manage communication preferences;

• Request feedback;

• Publish testimonials where express permission has been obtained;

• Operate, secure, troubleshoot and improve our website;

• Understand website traffic and how visitors use our website;

• Measure the effectiveness of our content and communications;

• Prevent fraud, misuse, security threats and other unlawful activity;

• Establish, exercise or defend legal rights;

• Meet legal, regulatory, insurance, accounting and tax requirements; and

• Complete a corporate transaction, such as a sale, financing, reorganization or transfer of the business, subject to appropriate confidentiality protections.

We will not use personal information for a materially different purpose without providing appropriate notice and obtaining consent where required.

5. Consent and Other Legal Grounds

We obtain consent in a form appropriate to the sensitivity of the information and the circumstances.
 

Consent may be:

• Express, such as selecting a checkbox, signing an agreement, providing written approval or choosing “Accept” on a cookie banner; or

• Implied, where the purpose is obvious and the information is not sensitive, such as providing an email address so we can respond to an inquiry.

We seek express consent before:

• Sending marketing emails where express consent is required;

• Publishing an identifiable testimonial;

• Using a client’s photograph, video or audio recording;

• Recording a private session;

• Collecting, using or disclosing sensitive information where express consent is appropriate; or

• Activating non-essential cookies where prior consent is required.

You may withdraw consent at any time, subject to legal, contractual or reasonable notice requirements. Withdrawing consent may affect our ability to provide a requested service.
 

Where European Economic Area or United Kingdom privacy law applies to a particular activity, we process personal information on one or more of the following grounds:

• Your consent;

• The need to enter into or perform a contract with you;

• Compliance with a legal obligation;

• Our legitimate interests in operating, securing and improving our business, where those interests are not overridden by your rights; or

• The establishment, exercise or defence of legal claims.

6. Cookies and Similar Technologies

Our website may use cookies, pixels, local storage, scripts and similar technologies.
 

Cookies are small files or pieces of information stored on or accessed through your device. They may be used to operate the website, remember preferences, analyze website use or support marketing activities.

Categories of cookies

Our website may use:
 

• Strictly necessary cookies
  
  These cookies support essential website functions, security, network management, accessibility, shopping-cart functions, payment processing and consent preferences. They generally cannot be disabled through our cookie banner. These cookies remember selections and provide enhanced website functions.
   

• Analytics cookies
  
  These cookies help us understand how visitors reach and use the website, which pages are viewed and how the website performs.

 

• Marketing cookies
  
  If used, these cookies may measure campaigns or support advertising across websites. We will not activate marketing cookies without the consent required by applicable law.

Cookie choices

Where required, non-essential analytics, functional and marketing cookies will remain disabled until you make a selection through our cookie banner.
 

The banner should allow you to:

• Accept non-essential cookies;

• Decline non-essential cookies;

• Select particular cookie categories; and

• Change or withdraw your selection later.

You may also manage cookies through your browser. Blocking cookies may affect some website functions.

Your consent choice may itself be stored in a necessary cookie so that the website can remember it.

7. Google Analytics
 

We may use Google Analytics 4 to understand website traffic and use.
 

Depending on our configuration and your consent choices, Google Analytics may collect information about:

• Your device and browser;

• Approximate geographic location;

• Pages viewed;

• Website interactions;

• Referring sources; and

• Visit duration and frequency.

We use this information in aggregated or statistical form to understand and improve our website and communications.

We will not knowingly send names, email addresses or other information that directly identifies you to Google Analytics.
 

Where consent is required, Google Analytics will not be activated until the appropriate permission has been provided through our cookie banner.
 

8. Embedded Content and Third-Party Features
 

Our website may contain embedded videos, scheduling tools, social-media content, forms, payment functions or other features supplied by third parties.
 

These providers may collect information directly from your browser or device and may use cookies or similar technologies. Where required, non-essential embedded features will not load until you provide the applicable cookie consent.
 

Your interaction with a third-party feature is also governed by that provider’s privacy policy and terms.
 

9. Email Marketing and Other Commercial Communications
 

You may choose to receive newsletters, announcements, program information and other marketing communications from us.
 

Where required, we obtain consent before sending commercial electronic messages. Our marketing messages will identify the sender and provide a functioning unsubscribe method.
 

You may unsubscribe at any time by:

• Selecting the unsubscribe link in an email; or

• Contacting us at [Insert email address].

We may retain limited information about your unsubscribe request so that we can honour it.

Unsubscribing from marketing does not prevent us from sending necessary transactional or service-related messages, such as booking confirmations, receipts, program information, security notices or responses to your inquiries.

We do not make consent to receive unrelated marketing a condition of purchasing a service.

10. Appointments and Video Conferencing

Appointments may be scheduled through a third-party platform such as Calendly, Wix Bookings or another scheduling provider.
 

The scheduling provider may collect your contact information, appointment details, time zone and information you enter into the booking form.

Private services may be delivered through Zoom, Google Meet or another video-conferencing platform.
 

We do not record private sessions unless:

• We have told you in advance why a recording is proposed;

• We have obtained your express consent; and

• We have explained how the recording will be used, stored and deleted.

11. Testimonials, Photographs and Client Stories

We publish identifiable testimonials, photographs, videos or client stories only with express permission.

Before publication, we will identify what we propose to use, such as:

• Your name;

• Professional title;

• Employer or business name;

• Photograph;

• Written comments;

• Audio or video; or

• Information about your experience or results.

You may withdraw your consent for future use by contacting us. We will stop new use and remove the content from platforms we control within a reasonable period.

Withdrawal may not allow us to retrieve material that was previously distributed, printed, downloaded, reposted by others or included in material that cannot reasonably be recalled.

We may use anonymous or aggregated feedback that does not reasonably identify you.

12. How We Disclose Personal Information

We do not sell or rent personal information.
 

We may provide limited personal information to service providers that perform functions on our behalf, including providers of:

• Website hosting and website management;

• Online forms;

• Scheduling and appointment management;

• Payment processing;

• Email and communication services;

• Newsletter delivery;

• Video conferencing;

• Cloud storage and document management;

• Website analytics;

• Information technology and security;

• Accounting, bookkeeping and tax services;

• Legal, insurance and professional advice; and

• Customer support.

Service providers are permitted to use personal information only as necessary to perform their services, subject to their contractual obligations and any independent legal obligations that apply to them.

We may also disclose personal information:

• With your direction or consent;

• To comply with a court order, subpoena, warrant or lawful request;

• To investigate fraud, misuse, security incidents or unlawful conduct;

• To protect our rights, property, safety or users;

• To establish, exercise or defend a legal claim;

• To collect a debt;

• In connection with a proposed or completed corporate transaction; or

• As otherwise permitted or required by law.

We do not disclose personal information to third parties for their own direct-marketing purposes without the consent required by law.

13. Processing Outside Canada

Auberon Consulting Limited is based in Ontario, Canada.

Some service providers may store or process personal information outside Ontario or outside Canada, including in the United States and other countries.

Personal information processed in another jurisdiction may be subject to that jurisdiction’s laws and may be accessible to courts, law-enforcement agencies, national-security authorities or other government institutions in accordance with local law.

We remain accountable for personal information transferred to service providers for processing on our behalf. We use reasonable contractual, administrative and technical measures appropriate to the nature and sensitivity of the information.

Where European Economic Area or United Kingdom transfer rules apply, we will use an available lawful transfer mechanism or require the relevant provider to maintain an appropriate transfer mechanism.

You may contact our Privacy Officer for information about the countries in which our principal service providers process personal information.

14. Retention and Disposal

We keep personal information only as long as reasonably necessary for the purposes described in this Privacy Policy and to meet legal, accounting, tax, insurance and dispute-resolution requirements.

Our general retention periods are:

• General inquiries that do not lead to a client relationship: normally up to 24 months after the last meaningful communication;

• Client service notes: normally up to three years after the last session or service, unless a longer period is reasonably required;

• Contracts, invoices, payment and accounting records: generally at least six years from the end of the tax year to which they relate, or longer where required;

• Marketing subscription records: while you remain subscribed;

• Consent and unsubscribe records: for as long as reasonably necessary to demonstrate and honour your communication choices;

• Testimonial permissions: while the testimonial is being used and for a reasonable period after use ends;

• Cookie-consent records: for the period configured in our consent-management system; and

• Analytics information: according to our configured analytics-retention settings and the provider’s applicable policies.

We may retain information longer if it is connected to a complaint, investigation, legal hold, threatened claim, unpaid account or another continuing legal requirement.

When personal information is no longer needed, we take reasonable steps to delete, destroy or anonymize it securely.

15. Security Safeguards

We use reasonable administrative, technical and physical safeguards appropriate to the sensitivity and amount of personal information under our control.

Safeguards may include:

• Limiting access to individuals who need the information;

• Password protection and multi-factor authentication;

• Secure cloud and payment providers;

• Device and account security controls;

• Confidentiality obligations;

• Software updates and security monitoring;

• Secure disposal procedures;

• Service-provider reviews; and

• Privacy and security procedures.

No website, internet transmission or electronic storage system is completely secure. We cannot guarantee absolute security, but we take reasonable steps to reduce foreseeable risks.

16. Privacy Incidents

We maintain procedures for responding to suspected loss, unauthorized access, disclosure or other privacy incidents.

When required by applicable law, we will:

• Investigate the incident;

• Take reasonable steps to contain and reduce harm;

• Keep required records;

• Notify affected individuals; and

• Report the incident to the appropriate privacy regulator.

17. Your Privacy Rights

Depending on applicable law and the circumstances, you may have the right to:

• Ask whether we hold personal information about you;

• Request access to that information;

• Ask how the information has been used or disclosed;

• Request correction of inaccurate or incomplete information;

• Withdraw consent;

• Request deletion of information that is no longer required;

• Object to or restrict certain uses;

• Request a copy of certain computerized information in a structured, commonly used technological format where a portability right applies;

• Ask us to send portable information to another authorized organization where legally required and technically feasible; and

• Submit a privacy complaint.

These rights are not absolute. We may need to retain or withhold information where permitted or required for legal, security, privilege, fraud-prevention, accounting, contractual or dispute-resolution reasons.

We may ask for information needed to verify your identity before responding. We will not use identity-verification information for an unrelated purpose.

We will respond within the period required by applicable law. We will explain any permitted refusal or limitation.

To exercise a privacy right, contact our Privacy Officer using the information in Section 2.

Additional European Economic Area and United Kingdom rights

Where European Economic Area or United Kingdom privacy law applies, you may also have the right to:

• Request erasure;

• Restrict processing;

• Object to processing based on legitimate interests;

• Object at any time to direct marketing;

• Receive certain information in a portable format;

• Withdraw consent without affecting prior lawful processing; and

• Complain to the supervisory authority in the country where you live or work.

18. Automated Decisions and Profiling

We do not use personal information to make decisions based exclusively on automated processing that produce legal or similarly significant effects concerning clients or prospective clients.
 

Website analytics may group or analyze website interactions, but we do not use that information to make significant automated decisions about individuals.

19. Children and Minors

Our website and services are intended for adults and professional audiences. They are not directed to children under 18.

We do not knowingly collect personal information from children under 18 through the website. A parent or guardian who believes that a child has provided personal information may contact our Privacy Officer to request its deletion.

20. Third-Party Websites

Our website may link to websites, social-media platforms or services that we do not operate.

We are not responsible for the privacy, security or content practices of independent third parties. Review the relevant third party’s privacy policy before providing personal information.
 

21. Changes to This Privacy Policy

We may revise this Privacy Policy as our services, technology, providers or legal obligations change.
 

The revised version will be posted on LaurelSimmons.com with an updated “Last updated” date.
 

Where a change materially affects how we use personal information already collected, we will provide additional notice or obtain consent where required.
 

22. Questions, Requests and Complaints

Questions, access requests and complaints should be sent to:

Privacy Officer
Auberon Consulting Limited
Email: privacy@laurelsimmons.com
Telephone: 905-641-1659
Mailing address: 9 Keith Crescent, Niagara-on-the-Lake, ON, L0S 1J0, Canada
 

We will acknowledge and investigate privacy complaints fairly and within a reasonable period.
 

If you are not satisfied with our response, you may be entitled to contact the Office of the Privacy Commissioner of Canada or another privacy regulator with jurisdiction over the matter, including the Commission d’accès à l’information du Québec where Quebec privacy law applies.

Individuals in the European Economic Area or United Kingdom may also have the right to complain to their applicable local data-protection supervisory authority.