1. Introduction
Ctl Holding AS ("we," "us," "our," or "the Company") operates the website ctlbreathing.ca (the "Website"). This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information when you visit our Website, use our services, or interact with us.
We are committed to protecting your privacy and ensuring you have a positive experience on our Website. This policy describes our privacy practices in compliance with applicable laws and regulations in Norway and Canada.
2. Information We Collect
2.1 Information You Provide Directly
We collect personal information that you voluntarily provide to us, including:
- Name and contact details (email address, phone number, postal address)
- Information about your interest in our breathing courses
- Course preferences and learning format preferences
- Messages and comments you submit through our contact forms
- Any other information you choose to provide when communicating with us
2.2 Information Collected Automatically
We may collect certain information automatically when you visit our Website, including:
- IP address and device identifiers
- Browser type and version, operating system
- Pages visited and time spent on each page
- Referring website and links clicked
- General geographic location (country/region level)
3. How We Use Your Information
We use the personal information we collect for the following purposes:
- Responding to your inquiries and providing customer support
- Processing course enrollment requests and providing course materials
- Sending course updates, newsletters, and educational content (with your consent)
- Improving our Website, courses, and services
- Conducting research and analytics to understand user behavior and preferences
- Complying with legal obligations and protecting against fraud
- Marketing and promoting our breathing courses (where permitted by law)
4. Legal Basis for Processing
We process your personal information based on the following legal grounds:
- Your explicit consent (where required)
- Fulfillment of a contract with you (course enrollment)
- Compliance with legal obligations
- Protection of our legitimate interests or the interests of others
- Pursuit of our legitimate business interests in improving services
5. Information Sharing and Disclosure
We do not sell, trade, or rent your personal information to third parties. However, we may share your information in the following circumstances:
- With service providers who assist us in operating our Website and delivering courses
- When required by law or legal process
- To protect our rights, privacy, safety, or property
- With your explicit consent
All service providers are bound by confidentiality agreements and are required to protect your personal information.
6. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Typically, we retain:
- Contact information: Until you request deletion or for the duration of your course enrollment
- Course enrollment records: For the duration of your course participation plus 7 years for legal compliance
- Website analytics data: Up to 24 months
You may request deletion of your personal information at any time, subject to legal retention requirements.
7. Your Rights
You have the following rights regarding your personal information:
- Right to Access: You can request a copy of the personal information we hold about you
- Right to Rectification: You can request correction of inaccurate information
- Right to Erasure: You can request deletion of your personal information
- Right to Restriction: You can request restriction of processing of your data
- Right to Data Portability: You can request your data in a portable format
- Right to Withdraw Consent: You can withdraw consent for processing at any time
- Right to Object: You can object to certain processing activities
To exercise any of these rights, please contact us at [email protected].
8. Cookies and Tracking Technologies
Our Website uses cookies and similar tracking technologies to enhance your browsing experience. Cookies are small files stored on your device that help us:
- Remember your preferences and settings
- Understand how you use our Website
- Improve Website performance and functionality
- Provide personalized content
You can control cookie settings through your browser preferences. Please refer to our Cookie Policy for more detailed information.
9. Security
We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- SSL/HTTPS encryption for data in transit
- Secure password protection
- Limited access to personal information by authorized personnel
- Regular security updates and monitoring
However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.
10. Third-Party Links
Our Website may contain links to third-party websites. We are not responsible for the privacy practices of external sites. We encourage you to review the privacy policies of any third-party websites before providing personal information.
11. Children's Privacy
Our Website and courses are not intended for children under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete such information promptly.
12. International Data Transfers
Ctl Holding AS is based in Norway. Your personal information may be transferred to, stored in, and processed in Norway and Canada. These jurisdictions may have data protection laws different from your country of residence. By using our Website and services, you consent to the transfer of your information as described in this policy.
13. Contact Us
If you have questions about this Privacy Policy, wish to exercise your rights, or have privacy concerns, please contact us:
14. Policy Changes
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our Website with a new "Last Updated" date.
Your continued use of our Website following the posting of changes constitutes your acceptance of the updated Privacy Policy.