Last Updated: January 15, 2024

spry dawn is committed to protecting the personal data of individuals in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This page provides information about your rights under GDPR and how we handle personal data.

Data Controller

spry dawn acts as the data controller for personal data collected through our website and services. Our contact information is:

spry dawn
350 Bay Street, Suite 1200
Toronto, Ontario M5H 2S6
Canada
Email: [email protected]

Legal Basis for Processing

We process personal data on the following legal bases:

  • Consent: When you have given clear consent for us to process your personal data for a specific purpose, such as receiving marketing communications.
  • Contract: When processing is necessary for the performance of a contract with you, such as providing our educational services.
  • Legal Obligation: When processing is necessary to comply with a legal obligation to which we are subject.
  • Legitimate Interests: When processing is necessary for our legitimate interests, provided these interests do not override your fundamental rights and freedoms.

Your Rights Under GDPR

If you are located in the European Economic Area (EEA), you have the following rights regarding your personal data:

Right to Access

You have the right to request a copy of the personal data we hold about you. We will provide this information free of charge within one month of receiving your request.

Right to Rectification

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

Right to Erasure (Right to be Forgotten)

You have the right to request the deletion of your personal data in certain circumstances, including:

  • When the data is no longer necessary for the purpose it was collected
  • When you withdraw consent and there is no other legal basis for processing
  • When you object to processing and there are no overriding legitimate grounds
  • When the data has been unlawfully processed

Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or when processing is unlawful.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance.

Right to Object

You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes. Upon objection, we will cease processing unless we can demonstrate compelling legitimate grounds.

Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Rights Related to Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.

How to Exercise Your Rights

To exercise any of your rights under GDPR, please contact us at:

Email: [email protected]

We will respond to your request within one month. In certain circumstances, we may extend this period by up to two additional months if the request is complex or if we receive multiple requests from you.

Data Transfers

As we are based in Canada, your personal data may be transferred to and processed in Canada. Canada has been recognized by the European Commission as providing an adequate level of data protection. We also implement appropriate safeguards to protect your data during any international transfers.

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. The retention period may vary depending on the context and our obligations.

Data Security

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

  • Encryption of personal data where appropriate
  • Regular testing and evaluation of security measures
  • Access controls limiting who can access personal data
  • Staff training on data protection practices

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly.

Right to Lodge a Complaint

If you believe that we have not complied with your data protection rights, you have the right to lodge a complaint with a supervisory authority. For residents of the EEA, you can file a complaint with the data protection authority in your country of residence.

Changes to This Information

We may update this GDPR information page from time to time. Any changes will be posted on this page with an updated revision date.

Contact Us

If you have questions about GDPR compliance or your data protection rights, please contact us at:

spry dawn
350 Bay Street, Suite 1200
Toronto, Ontario M5H 2S6
Canada
Email: [email protected]