Privacy policy

Latest Update: 19 august 2024

Hello there! We are Operam Technologies Inc. (“Operam”, “we”, “us”, “our”).

This Privacy Policy applies when you:
- navigate on our website at http://www.oplan.ca/ (the “Website”);
- interact with us on social media, through live chat, by emails or otherwise; and/or
- use our Oplan planner and time management app, available through a web app at https://oplan.app/ (the “App”); (together, the “Services”)

Our App has different user interfaces designed specifically for student users (“Student Users”), for their teachers & school administrators (“Teacher Users” and together with the Student Users, the “App Users”). For the purpose of this Privacy Policy, individuals who are navigating our Website will be referred to as “Website Users” (together with the App Users, the “Users”).

This Privacy Policy is addressed to all Users over the age of 16, as well as to parents and/or guardians of Student Users aged 16 or under , where applicable, and provides comprehensive information on how we handle personal information as well as your rights as Users and/or parents.

Our Services may contain links to external services that are not part of the Services. For example, a Teacher User may provide a Student User with a link to a website to learn more about a certain topic. Such external services and content are not covered by this Privacy Policy.

If you wish to contact us regarding our privacy practices, to exercise your rights, or if you have any questions or concerns, you may do so by e-mail at info@oplan.ca, or by mail at the following address:

Privacy Officer
Operam Technologies Inc.
81 Rue Notre Dame O,
Thetford Mines, QC G6G 1J4
Canada

This Privacy Policy also covers the use of Teacher Users’ data for interest-based advertising. For more information about this topic, please scroll to the relevant section of this Privacy Policy. We do not conduct interest-based advertising on personal information of Student Users when they use our App.

1. What is personal information?

This Privacy Policy applies to personal information. We consider personal information to be any information that allows us to identify you directly or indirectly, including "cookies" and other electronic data. Some information may not be personal in itself but may become so if combined with other information or if the sum of the information allows us to identify individuals.

A "cookie" is a piece of information that a website places on a computer’s hard drive so that a website or web application can remember something about individuals at a later date. In this Privacy Policy, when we refer to "cookies", we also include other technologies with similar purposes, such as pixels, tags and web beacons. For more information on “cookies”, you can consult websites such as http://www.cookiecentral.com/ and https://www.allaboutcookies.org/.

This Privacy Policy is intended to provide transparency and some of the data we identify in this Privacy Policy as personal information may not be protected as personal information under applicable laws.

2. What personal information do you collect about me and for what purposes?
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We collect personal information to provide you with our Services for the purpose of conducting marketing activities and obtaining analyses. Please refer to the table below to learn more about the types of data collected, the purposes pursued as well as, where the General Data Protection Regulation ("GDPR") applies, the applicable legal basis for processing. In Canada, we must rely on your consent, except where a legal exception applies.
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Identification & Communication Data

Emails;
Last name;
First name;
Phone number;
Content of communications.

To subscribe Website Users to our newsletters, inform you of our offers, promotions and new features. We also collect this information if Website Users request a demonstration of our Application or subscribe to our newsletter. (Legal basis applicable from the point of view of the GDPR: consent)

Cookies & Electronic Data

IP address;
Device and browser information;
Screen resolution;
Operating system name and version;
Device manufacturer and model.

This information is used to correct computer problems, remember important information, display the website in your preferred language and enhance security. Proceed to section 3 to access the question regarding our "cookies" and other tracking technologies. (Applicable Legal basis applicable from the point of view of the GDPR: the performance of a contract or consent, depending on the type of cookie)

Educational & Identification Information

Name of Users;
Type of User account;
Classes that Student Users are enrolled in;
email addresses of Users;
Teacher Users specialization;
Other information which educational institutions may deem necessary, such as student IDs.

When we integrate new educational institutions, we receive this information from educational institutions or parents, as the case may be, and it is used to create accounts or manage the accounts of Student Users and Teacher Users. (Legal basis applicable from the point of view of the GDPR: consent and the performance of a contract).

Identifiers:

Email address;
Passwords.

Once accounts have been created, Application Users can log in using their username (e-mail address) and password. Information for each account includes full name, username, email address, password and grade levels for Student Users. (Legal basis applicable from the point of view of the GDPR: consent)

User Generated Information

Work plan;
Tasks description;
Time schedule;
Classification data.

Students can also access live classes, where they can share files and use a digital whiteboard. Each session is recorded in the history tab and associated with an ID. All session transcripts are accessible to both Student Users and Teacher Users. User-generated information is also used to create reports for Teacher Users and parents of Student Users.

We process User-Generated Information in order to offer our Application to educational institutions, in particular to enable Student Users to benefit from tutoring services, as well as to enable Teacher Users and parents to supervise the activities of their students/children within our Application. (Legal basis applicable from the point of view of the GDPR: consent and the performance of a contract).

Electronic Data

IP address;
Device and browser information;
Screen resolution;
Operating system name and version;
Device manufacturer and model.

This information is used to correct computer problems, remember important information, display the Services in the preferred language and reinforce security. Electronic Data is also used to send notifications to users about activities within the Services. Our Services may also include browser notifications that require Electronic Data. (Legal basis applicable from the point of view of the GDPR: consent and the performance of a contract, depending on the type of component used such as “cookies” whether they are essential or not).

Usage Data

Time spent on the App;
Pages visited;
Links clicked;
Language preferences;
Pages that led or referred you to the App.

In order to understand how our Application behaves and what features are used, we collect Usage and Performance Data. This may include computer problems, errors and logs generated by Users, as well as other data collected using an anonymous identifier associated with Users. This personal information may be used for support, maintenance and troubleshooting purposes. (Legal basis applicable from the point of view of the GDPR: consent)

3. What types of cookies and other tracking technologies do you collect, and for what purposes?

"Cookies" are small text files stored in the memory of a computer's web browser. When we use the term "cookies" in this policy, we also include similar tracking technologies such as pixel tags (also known as web beacons and clear GIFs). We also collect mobile advertising identifiers, which are then used to serve our ads. We may use both internal "cookies" (set by us) and third-party "cookies" (set by our partners and service providers). We use four (4) types of cookies: essential, analytical, functional and marketing.
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Essential

Essential “cookies” are necessary for the operation of the website and our Application. These include connection "cookies", session identification "cookies", language "cookies" as well as security "cookies". (Legal basis applicable from the point of view of the GDPR: the performance of a contract)

Analytical

Analytical "cookies" are placed on our website and Application to provide us with information about how you use our Services, which pages you like and which advertisements work. Analytical "cookies" track visitors to our website to understand their browsing behavior and length of visit. We use analytics to measure usage, and we do not identify you individually when we perform analytics. For example, we use _ga, a "cookie" operated by Google Analytics. (Legal basis applicable from the point of view of the GDPR: consent)

Functional

Functional "cookies" record information about the choices you have made and enable us to personalize our website for you. This includes preferences such as your location. (Legal basis applicable from the point of view of the GDPR: consent)

Marketing

Marketing "cookies" are used to track Users across websites and devices in order to deliver advertising tailored to their behavior (behavioral targeting). These "cookies" are often provided by third-party companies. (Legal basis applicable from the GDPR point of view: consent)

‍We do not use marketing “cookies” or mobile advertising identifiers in the Student User interface.

4. How do you obtain consent from Student Users?
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Most students who use our Application cannot give consent to the processing of their personal information under applicable laws. Verifiable parental consent is then required. Educational institutions using our Services are responsible for obtaining such consent from parents and/or guardians in accordance with applicable laws.

5. Where do you store personal information?

We host, in Quebec, personal information of individuals located in Quebec, Canada, those concerning individuals located in the European Union will be stored in France. Those concerning individuals located in the United States will be stored in the United States. However, we use third-party service providers that may be located in other countries. In such cases, we enter into binding agreements with these third parties to ensure that personal information remains protected in a manner substantially similar to the protection afforded by Quebec privacy laws.

6. How do you protect personal information?

We seek to implement risk-proportionate controls to protect the privacy of Student Users and other Users. For example, we use multi-factor authentication, SSL encryption, access logging, physical access controls to files and buildings, and secure file transfer protocols with encryption. Our cloud service provider, Google Cloud Platform, maintains several independent audits of its security, privacy and compliance controls, such as ISO 27017, ISO 27018 and ISO 27001. You can view Google Cloud Platform guarantees on the Google Trust & Security Center.

We also expect and require our service providers to provide an adequate level of security for personal data.

7. How long do you retain personal information?

We retain personal information for as long as necessary to comply with applicable laws or to fulfill the purposes described above.
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8. Whom do you disclose personal information to?

We do not sell your personal information to data brokers. Where permitted by applicable law, we conduct digital marketing using marketing partners and perform analytics with other IT service providers. We may transfer ownership of your data in the event of a merger, acquisition or other corporate transaction. We may share your personal information with authorities if justified and required by applicable laws.

This section does not apply to the personal information of Student Users. Please refer to the next section of this Privacy Policy which deals with this subject.
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Marketing Partners

We work with marketing partners to manage our customer database and target Teacher Users who have not completed their registration. To this end, we carry out interest-based advertising or advertising "retargeting". We also work with SEO consultants and other marketing consultants.

Analytics Partners

We use third parties to obtain analytics, in particular through "cookies" such as Google Analytics.

Service Providers

We use service providers to supply us with information technologies such as data hosting or to provide certain functionalities of our services.

Law Enforcement, Regulatory Authorities

If we receive a lawful request from the appropriate authorities, we may be required by law to share your personal information. We take care to share only what we are required to share by law.

Corporate Transactions

In the context of a merger and acquisition, the sale of our assets, bankruptcy and other corporate transactions, your personal information will be considered our assets and may be transferred to such third parties. Such third parties will be bound by applicable laws and by this Privacy Policy.

The Services may offer the possibility of connecting to other websites and applications. If you click on links to third parties or advertisements, these third parties are not our providers and they process your personal information according to their own privacy policies, which you should review. We are not responsible for the content or privacy practices of these third parties.

We may also share your personal information with our auditors and consultants if they are subject to an obligation of confidentiality and reasonably require access to such information in the course of their engagement with us.
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9. Whom do you disclose Student Users personal information to?

We do not sell any personal information of our Student Users, and we do not use personal information for any purpose other than to provide the Services. This means that we do not use Student Users' personal information for marketing, interest-based advertising or retargeting purposes using “cookies” in the Student User interface, and we do not use marketing "cookies" in the Student User interface of the Application. We are subject to the same conditions of use and disclosure of educational records as school officials under the Family Educational Rights and Privacy Act (FERPA). This means that we share personal information only as necessary for the Services and with third parties who have a legitimate educational interest, unless otherwise authorized or required by law.

If we receive a request for access to personal information from the authorities, we will transfer this request to the educational institutions. If the law prevents us from doing so or requires us to respond, we will first validate that the request is legitimate and disclose the minimum required with the help of legal counsel.

All personal information of Student Users collected through the Application is accessible to and may be consulted by Teacher Users.

The following are the categories of recipients with whom your personal data is shared so that we can provide you with the features within the scope of our Services. Each service provider is bound by an agreement with us that limits their rights to use your personal data for other purposes :
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IT Service providers

We use Elastic Search to manage our Users and provide adequate support.

We host Student Users' personal information on Google Cloud Platform in Quebec, Canada (for Student Users located in Europe, we host data on servers located in France).

We use Firebase to correct computer problems and improve the functionality of our Application, and not for advertising or any other purpose.

We may use other service providers who have access to “cookies” and electronic data for security purposes or as part of our architecture. We cannot share the identity and contact details of these service providers to protect our infrastructure from attack. If you have any questions, please contact us using the contact details provided at the top of this Privacy Policy.

Law Enforcement, Regulatory Authorities

If we receive a lawful request from the appropriate authorities, we may be required by law to share Student Users' personal information. We will only share what we are required to share by law. Where possible, in accordance with applicable law, we will notify you before disclosing Student Users' personal information to law enforcement or regulatory authorities.

Law enforcement and regulatory authorities are subject to their own legal obligations regarding the collection of personal information about Student Users. These measures are exceptional.

Corporate Transactions

In the context of a merger and acquisition, the sale of our assets, bankruptcy and other corporate transactions, Student Users' personal information will be considered our assets and, therefore, may be transferred to such third parties. Such third parties will be bound by applicable laws and by this Privacy Policy.

Our Services can be integrated with other learning management platforms via single sign-on and APIs, such as Google Classroom, Moodle and Canvas. Integration Partners are not our suppliers or service providers. Educational institutions enter into separate agreements with Integration Partners to which we are not a party, and plug-ins, APIs or other access to Integration Partners are activated only at the request of educational institutions. This enables educational institutions to integrate our Services with other educational technologies and services relevant to students, in order to simplify education. If we are required to do so to comply with educational institutions' instructions, we may share personal information with these integration partners. Educational institutions have full control over the personal information they share.
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10. Do you conduct interest-based advertising?

As you browse our website, we and certain third parties collect information about your online activities over time and across different sites to provide you with advertisements about products and services tailored to your individual interests. This is known as "interest-based advertising" (IBA). These third parties may place or recognize a unique cookie or other technology on your browser (including the use of pixel tags). Where required by applicable law, we will obtain your consent before processing your information for interest-based advertising purposes. We never authorize IBA when Student Users use our Application.

‍You may see our advertisements on other websites or mobile applications, as we participate in advertising networks. Ad networks enable us to target our advertising messages based on a variety of factors, including demographics, interests inferred from Users and browsing context (for example, the time and date you visited our website, the pages you viewed and the links you clicked). This technology also helps us track the effectiveness of our marketing efforts and understand whether you have seen any of our advertisements.

We may display interest-based advertising to you when you use social media, such as with Facebook's Conversion Tracking Pixel and Facebook's Custom Audience Tool. This allows us to personalize our ads based on your behavior with us, for example if you haven't completed your registration, and to record the effectiveness of our ads for statistical and market research purposes. The data collected remains anonymous. We do not share any of your personal information, including your behavior, with Facebook. The Custom Audience Tool allows us to convert your e-mail address into a unique number that Facebook uses to match the unique numbers it generates from its users' e-mail addresses as part of the advertising network. Depending on the authorization you have given Facebook, it may use your data for advertising purposes, in accordance with its privacy policy, which you can find here.

We work with Google Analytics, Google AdWords and other advertising networks. To find out how to opt out of behavioral advertising from Network Advertising Initiative member companies, please visit the Network Advertising Initiative and Digital Advertising Alliance. websites. You can download the AppChoices app to unsubscribe from mobile applications. If you choose to opt out of interest-based advertising, you may see ads that are not relevant to you. Currently, there is no industry standard for recognizing Do Not Track signals from browsers, so we do not respond to them.

11. What are my rights regarding my personal information?

The extent of your rights depends on the laws applicable to the processing of your personal information, so your rights may vary. Refer to the table below to find out more about the rights applicable depending on where you are located.
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Access

You have the right to obtain confirmation as to the processing of your personal information held by Operam and to have access to it (i.e. to examine it and obtain a copy).

Canada and Europe

Rectification

You have the right to obtain rectification of personal information held by Operam that is inaccurate or misleading.

Operam further acknowledges that, given the purposes of the processing, you have the right to have your incomplete personal information completed, including by providing a supplementary declaration.

Canada and Europe

Withdrawal of consent

You have the right to withdraw your consent to the processing of your personal information. Operam will comply with your request, unless Operam demonstrates compelling legitimate grounds for the processing that prevail under the GDPR.

Canada and Europe

Right to erasure

You have the right to obtain from Operam the erasure, as soon as possible, of personal information about you where one of the grounds set out in the GDPR applies, in particular, where your personal information is no longer necessary for the purposes for which it was collected or otherwise processed.

Europe

Portability

Unless it would cause serious practical difficulties, you may have the right to receive the personal information about you that you have provided to Operam in a structured and commonly used format.

Canada and Europe

Opposition

You may have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on the public interest or the legitimate interest of the controller, including profiling.

Operam will comply with the request, unless Operam demonstrates that there are compelling legitimate grounds for the processing that override the interests and rights and freedoms of the individual or that the processing is necessary for the establishment, exercise or defense of Operam's legal claims.

Europe

Limitation

You may avail yourself of the right to restrict the processing of your personal information in certain circumstances. This means that you can limit how Operam uses your personal information when one of the conditions set out in the GDPR applies.

Europe

Right to use automated decision-making systems

In some cases, you may request information about the use of any automated decision system and the impact it may have on you.

Europe

If you would like to find out more about your rights under the GDPR, you can visit the European Commission's data protection page at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_fr .

We are not currently subject to the California Consumer Privacy Act, and we do not respond to Do Not Track signals. However, if you have a legitimate request regarding your personal information, we will do our best to assist you.

You can send your request by e-mail to info@oplan.ca, or by post to the address given at the beginning of this Privacy Policy. Before responding to your request, we will need to confirm your identity.

We may also refuse to respond to your request if applicable laws do not permit the exercise of certain rights or for other valid and legal reasons. If we are unable to respond, we will inform you of the reasons. We will respond to your request within 30 days, or within the legal period prescribed by law.

If you are not satisfied with the way your request has been handled, you can file a complaint with your local authorities. For example, in Canada, you can file your complaint with the Office of the Privacy Commissioner by consulting the information available here.

12. What are parents’ rights regarding the personal information that you collect about their Student Users when they use the App?

We require Student Users to disclose only the personal information that is reasonably necessary to participate in an activity. You have the right to review the personal information we collect about your Student Users, and you may monitor their accounts with us at any time.

We do not authorize the disclosure of Student Users' personal information to third parties, except to the extent strictly necessary to provide the Services. We process Student Users' personal information only with your explicit consent. We obtain your explicit and verifiable consent through the institutions that are responsible for obtaining such valid consents from parents and/or guardians.

You can send your request by e-mail to info@oplan.ca or by post to the address given at the beginning of this Privacy Policy. Before responding to your request, we will need to confirm your identity. We will respond to your request within 30 days or as required by applicable law.

Depending on your location, different rights may apply. However, students can't always exercise their rights themselves and may need a parent to do so. For example, the U.S. Educational Rights and Privacy Act (FERPA) gives rights to eligible students (i.e., those over 18) or parents to ask a school to correct records they believe are inaccurate or misleading. In many cases, the educational institution where the student is enrolled is the best entity to contact to exercise privacy rights, as it holds complete student records. We may be prevented by law from responding to requests to exercise certain privacy rights, such as access to student records, without the authorization of the educational institution concerned.

If you are not satisfied with the way we have handled your request, you may file a complaint with your local authority. For example, in the U.S., you can contact the Federal Trade Commission by visiting ftc.gov or calling toll-free 1-877-FTC-HELP. You can also watch this video on how to file a complaint.

13. Can I manage my preferences regarding cookies?

Yes ! However, some features of our website may require the use of “cookies” to function for example, in order to make payments. You can manage your cookie preferences via your browser.

14. Can I unsubscribe from your newsletters?

Yes, you can unsubscribe from our newsletters at any time by clicking the unsubscribe link in our emails. You can also write to us directly at info@oplan.ca.

15. Can I delete my account with you?

Yes, you can delete your account entirely by reaching out to us at info@oplan.ca. You can delete a Student Users account at any time, however, once you do so, all your data relating to this Student User will be lost.

16. Can you change this Privacy Policy?

Yes, we plan to add many new features and continue to develop our Services. As a result, we may need to change this Privacy Policy to reflect how we handle personal information over time. We may also change this Privacy Policy to reflect new legislation, new technologies or if reasonably necessary. If we change this Privacy Policy, we will notify our Users by e-mail. If you continue to use our Services, you will be deemed to have accepted these changes. You can refer to the date of last update above to find out when we last updated our Privacy Policy.
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