GDPR Compliance

Our Commitment to GDPR

Crisp-atoll is committed to complying with the General Data Protection Regulation (GDPR) and protecting the privacy rights of individuals in the European Economic Area (EEA), United Kingdom, and Switzerland.

Legal Basis for Processing

We process personal data under the following legal bases:

• Consent: When you voluntarily provide information through enrollment forms or email subscriptions
• Contract Performance: To deliver educational services you have enrolled in
• Legitimate Interests: To improve our services and communicate about relevant programs
• Legal Obligations: To comply with applicable laws and regulations

Your Rights Under GDPR

As a data subject, you have the following rights:

Right to Access

You may request confirmation of whether we process your personal data and obtain a copy of the data we hold about you.

Right to Rectification

You may request correction of inaccurate or incomplete personal data.

Right to Erasure

You may request deletion of your personal data in certain circumstances, including when the data is no longer necessary for the purposes for which it was collected.

Right to Restriction of Processing

You may request that we limit the processing of your personal data in specific situations, such as when you contest the accuracy of the data.

Right to Data Portability

You may request to receive your personal data in a structured, commonly used, and machine-readable format and have it transmitted to another controller.

Right to Object

You may object to processing of your personal data based on legitimate interests or for direct marketing purposes.

Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing that produces legal effects or similarly significantly affects you. We do not engage in automated decision-making of this nature.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing before the withdrawal.

How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: [email protected]
Subject line: GDPR Rights Request

We will respond to your request within 30 days. In complex cases, we may extend this period by an additional 60 days and will inform you of the extension.

Data Protection Officer

For questions about our GDPR compliance or data protection practices, you may contact our designated Data Protection Officer at [email protected].

International Data Transfers

When we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions recognizing equivalent data protection levels
• Other legally recognized transfer mechanisms

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specific retention periods include:

• Enrollment and program participation records: 7 years after program completion
• Marketing communications: Until consent is withdrawn or 3 years of inactivity
• Website analytics data: 26 months
• Financial records: As required by applicable tax and accounting laws

Data Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

• Encryption of data in transit and at rest
• Regular security assessments and vulnerability testing
• Access controls and authentication requirements
• Employee training on data protection principles
• Incident response procedures

Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by GDPR.

Third-Party Processing

We work with third-party service providers who process personal data on our behalf. These processors are contractually obligated to:

• Process data only according to our documented instructions
• Implement appropriate security measures
• Assist us in responding to data subject requests
• Notify us of any data breaches
• Delete or return data upon termination of services

Children's Data

We do not knowingly process personal data of individuals under 16 years of age without parental consent. If we become aware of such processing, we will take steps to delete the data.

Right to Lodge a Complaint

If you believe we have not adequately addressed your concerns, you have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or where an alleged infringement occurred.

Updates to This Statement

We may update this GDPR compliance statement to reflect changes in our practices or legal requirements. Material changes will be communicated through our website or direct notification.

Contact Information

For questions about GDPR compliance or to exercise your rights:

Crisp-atoll
487 Wellington Street West, Suite 302
Toronto, ON M5V 1E3
Canada
Email: [email protected]