Effective: September 23, 2022

Enriched Academy Inc. (collectively, “Enriched”, “we,” “us,” “our”) respects your privacy and are committed to protecting it by complying with this privacy policy (this “Policy”).

We are dedicated to protecting your privacy and safeguarding your personal information. This Policy describes:

• how we collect, use, disclose, and protect the personal information of our customers and users of the Sites ("you");
• the types of information we may collect from you or that you may provide when you visit enrichedstart.com, dragonbank.com or enrichedacademy.com (collectively, the “Sites”); and
• our practices for collecting, using, maintaining, protecting, and disclosing your personal information.

This Policy outlines the privacy practices and procedures concerning the personal information we collect, use or disclose about you on the Sites, in email, text and other electronic messages between you and the Sites, and through mobile and desktop applications you download from the Sites, which provide dedicated non-browser-based interaction between you and the Sites.

The Sites may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website, network or application, or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. Enriched is not responsible for the privacy practices or content of third-party websites, platforms, networks or plug-ins. This Policy does not apply to data processed and/or collected exclusively by third parties and we have no influence over the policies and procedures of such third parties. We encourage you to read the privacy policy of every third-party website, platform, network or plug-in you visit or use.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your information. You should read this Policy in conjunction with the Terms of Use Agreement for the Sites as both of these govern your use of and access to the Sites. If you do not agree with our policies and practices, your choice is not to use our Sites. By accessing or using the Sites, you indicate that you understand, accept, and consent to the practices described in this Policy. This Policy may change from time to time (see Section on Changes to Our Privacy Policy). Your continued use of the Sites after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

If you are using the Sites on behalf of any person, you confirm that you are legally authorized to accept the terms and conditions of this Policy on such person’s behalf.

The Sites are not intended for any person under 13 years of age. Please see below for the section on the Use and Disclosure of Personal Information for Minors.

The types of information that we collect include:

• Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, your Account Information (as defined below), and any other identifier we may use to contact you ("personal information"). It also includes information you provide about yourself if you correspond with us requesting assistance or other services.

  We also collect information about which services you access or subscribe to on the Sites, about your progress in the training provided on the Sites and the results of any quizzes or evaluations that you complete. If you use any of tools within the Site for simulation purposes (for example, the Net Worth Tracker), any information you input into the tools will be retained by the Site.

• Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific feature of the Sites or showcase traffic patterns for the Sites.

• Special requests may be made to request that you provide us, at your discretion, with personal information in connection with special requests such as surveys, contests or special offers. When the answers/responses you provide can be attributed to you, they are treated as personal information.

• Technical information such as your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access the Sites, the name of the Internet domain you used to access the Internet, the IP address of the web site from which you linked directly to our Sites, the date and time you accessed a Site, the pages you visited, and usage details. We use this technical information to monitor the effectiveness of the Sites and to consider potential improvements to the Sites. When technical information can be attributed to you as an individual, it will be treated as personal information.

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
• Through the Sites from a school, educational institution, teacher or other organization in order to register you on the Sites.
• User contributions when you may, voluntarily, provide information for us to publish or display on public areas of the Sites or transmit to other users of the Sites or third parties. Any content that users upload to the Site remain the copyright of the User.
• Automated technologies or interactions, as you navigate through our Sites. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

You may also provide information to be published or displayed (hereinafter, "posted") on public areas of the Sites or transmitted to other users of the Sites or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Sites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

As you navigate through and interact with the Sites, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Sites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Sites.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is technical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third party login services when you link to the Sites through those services (for example – Google). It helps us to improve the Sites and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Sites according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Sites.

The technologies we use for this automatic data collection may include:

• Cookies (or session cookies). A cookie is a small file placed on the hard drive of your computer, and session cookies are temporary cookie files which are erased when you close your browser. When you restart your browser and go back to the site that created the cookie, the website will not recognize you. You will have to log back in (if login is required) or select your preferences/themes again if the Site uses these features. A new session cookie will be generated, which will store your browsing information and will be active until you leave the site and close your browser. You can choose whether to accept cookies by adjusting the settings of your browser. If your browser is set to reject cookies, you may still be able to use the Sites, but your use may be limited to certain minimal functionality.

• Web Beacons. Pages of the Sites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Enriched, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We use the personal information that we collect about you:

• To present the Sites and their contents to you.
• To provide you with information, products, training or other services that you request from us.
• To track your progress in training you request from us.
• To provide you with notices about your account or subscription, including expiration and renewal notices.
• 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 requirements.
• To notify you about changes to the Sites or any products or services we offer or provide though the Sites. This may include sending newsletters, messages about new Enriched features, Enriched special offers, promotional announcements, consumer surveys and other correspondence concerning our service. Occasionally, we may send these materials to you via postal mail.
• To improve the Sites, products or services, marketing, or customer relationships and experiences.
• To allow you to participate in interactive features, social media, or similar features on the Sites.
• To fulfill the purposes for which you provided the information or that were described when it was collected.
• For any other purpose with your consent.

Enriched Academy does not track user behaviour outside of the Sites. For example, there is no tracking of user browsing habits, search queries or use of social media.

If you no longer want to receive newsletters or other announcements, you can opt out of receiving further communications from Enriched by contacting us at [email protected].

In addition, we may use your information to contact you about our own and third-parties' goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please use the unsubscribe mechanism at the bottom of our emails or email us at [email protected].

We will not sell, share, transfer, rent or otherwise provide any personal information to others in ways different from what is disclosed in this Privacy Policy. Enriched reserves the right to collect, disseminate, sell or otherwise disclose non-personal information provided by you. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect to the following third parties:

• To our subsidiaries and affiliates.
• To the organization through which you registered to access the services available on our Sites. The personal information disclosed in these circumstances will be limited to your progress in our training, and your marks on quizzes and evaluations.
• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Enriched's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Enriched about our customers and users is among the assets transferred. If such transfer occurs, we will use commercially reasonable efforts to ensure that the buyer or successor, as the case may be, maintains privacy policies similar to those of this Policy.
• To third parties to market their products or services to you if you have consented to these disclosures. For example, Enriched may partner with third parties to provide specific services such as making charitable donations. When you request such services, Enriched will share your personal information to such third parties for them to provide the services. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with improvement and optimization of the Sites) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To fulfill the purpose for which you provide it and any other purpose disclosed by us when you provide the information.
• For any other purpose with your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our Terms of Use Agreement and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Enriched, our customers, or others. This includes:
• exchanging information with other companies and organizations for the purposes of fraud protection, intellectual property rights protection, and credit risk reduction;
• enforcing applicable sections of any agreement between you and Enriched, including investigation of potential violations thereof;
• detecting, preventing or otherwise addressing fraud, security or technical issues; or
• protecting against imminent harm to the rights, property or safety of Enriched, its users or the public as required or permitted by law.

When we disclose your personal information, we will only disclose the minimum amount of personal information necessary for the purpose for which the information is disclosed.

We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All safety and security measures are appropriate to the sensitivity level of the information collected.

All personal information we collect is hosted on servers in Canada. Some of the service providers we use to support our business may be located outside Canada. Your personal information will still be protected by appropriate safeguards but it may be accessible by foreign government agencies under their applicable law.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Sites, you are responsible for keeping this password confidential and to not to share your password with anyone. It is important for you to protect against unauthorized access to your password and to your computer or other device that you use to access the Sites.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites. Enriched shall not be liable for the transfer of any personal information resulting from loss or distribution of data, the corruption of storage media, power failures, natural phenomena, riots, acts of vandalism, sabotage, terrorism or any other event beyond our control.

The Sites may contain links to other sites that are not necessarily under the control of Enriched. Enriched is not responsible for the privacy practices of such other sites and encourages you to be aware when you leave the Sites and to read the privacy policies of each and every web site that collects personally identifiable information.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you and without your consent.

The security of your personal information is important to us; please advise our privacy officer immediately of any incident involving the loss or unauthorized access to or disclosure of personal information that is in our custody or control.

Employees of Enriched are required to immediately report any breach of privacy, or suspected breach of privacy, to Enriched’s privacy officer. A breach of privacy includes unauthorized external or internal access to our physical records or electronic records, misdirected communications, including mail, fax, and electronic communications, and the loss or theft of physical records or electronic records stored on data storage devices.

Enriched’s privacy officer will coordinate a review of the matter and investigate all reported privacy breaches or suspected privacy breaches, all in accordance with Enriched’s breach protocols. Where a privacy breach has occurred, we may notify the affected individuals and may report the breach to the relevant privacy commissioner or to the appropriate authorities, including the police.

The Sites are not intended to be used by children under 13 years of age. The information products, training and other services offered on the Sites are offered to adults or to minors between the ages of 13-18 through schools.

By default, minors will be opted-out of newsletters, messages about new Enriched features, Enriched special offers, promotional announcements, consumer surveys, other correspondence concerning our service and out of disclosure to third parties for advertising purposes.

We will only request the minimum amount of personal information about minors necessary to provide the Services requested. It is our policy not to condition participation in an activity on collection, use or disclosure of more personal Information than is reasonably necessary to participate in the activity.

If a minor has submitted personal information, the parents or guardians of such minor may:

• review the personal information at any time;
• require us to delete all personal information about the minor; or
• refuse the further collection or use of the minor’s personal information by contacting our privacy officer.

Parents and guardians have the right to consent to our collection and use of their minor’s personal information while prohibiting disclosure of personal information to third parties that are not providing support for the internal operations of the Sites, and this can be done by contacting us at [email protected].

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

If your personal information changes (such as your email or address), you can update your information on the user profile pages of the Sites. If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. If you wish to deactivate your account, you can contact [email protected].  If 10 years have gone by without you accessing the Site or your account, we will send a reminder notice to you. If we do not hear back within 60 days from that notification, we will delete your account and your personal information.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at [email protected].

If you delete your User Contributions from the Sites, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users of the Sites.

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certaincircumstances. To withdraw your consent, if applicable, contact us at [email protected].

Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat your personal information, we will notify you through a notice on the home page or user dashboard. You agree to be bound by this Policy and any modifications to this Policy occurring prior to your continued use of the Sites. We include the date the privacy policy was last revised at the top of this page. You are responsible to visit this page from time to time to review the current terms of this Policy because they shall be binding on you. Certain provisions of this Policy may be superseded by expressly designated legal notices or terms located on particular pages at the Sites.

We are committed to having an accessible and responsible complaint handling process in place to ensure you can express concerns about Enriched’s compliance with privacy legislation and other regulatory requirements. Any complaints, disputes, or other feedback concerning our privacy practices, procedures, and this Policy should be submitted directly to our privacy officer. We have established appropriate organizational protocols to respond to such inquiries and will, where appropriate, provide a written response to you or amend our privacy practices and procedures or this Policy.

If there is a dispute regarding your personal information or this Policy, you agree to use reasonable efforts to resolve such dispute with us informally and to consult and negotiate with us in good faith to reach a fair and equitable solution.

If the dispute is not resolved through an informal process within 30 days, either you or we may consult the relevant provincial or federal privacy commissioner.

As necessary, Enriched may send you announcements and updates regarding the Sites. Enriched communicates via email with you to provide requested services and to resolve issues relating to your account.

Please contact our Privacy Officer to obtain further information about our policies and procedures or if you have any unresolved enquiries or concerns. Our Privacy Officer can be contacted as follows: