Aryval Ltd. PRIVACY POLICY
Last revised: February 21, 2025
Aryval Ltd. (“Aryval“, “we“, “us“, or “our“) values the privacy of individuals who use Aryval’s Website (as defined below), software products and related documentation, and other products and services we may offer, from time to time (collectively, the “Services“). This “Privacy Policy” describes: (1) the personal information we gather from parents and schools that access or use the Services (collectively, “users“, “you“, or “your“); (2) how we use and disclose such information; and (3) the steps we take to protect such information. By using the Services, you consent to our privacy practices, as described in this Privacy Policy.
As encouraged by the Personal Information Protection and Electronic Documents Act (“PIPEDA“), the commentary in this Privacy Policy has been drafted to reflect privacy issues specific to Aryval. We will continue to review this Privacy Policy to make sure that it remains current with exceptions, changing technologies, industry standards and applicable laws. If we make changes to this Privacy Policy, a revised version will be posted on our Website. In the event any modification is material, we will provide you with reasonable notice before such modifications take effect. Your continued use of the Services thereafter constitutes your acceptance of such modifications.
- Definitions
collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. The form of consent we seek may vary, depending upon the circumstances and the type of personal information. In determining the form of consent, we take into account the sensitivity of the personal information and your reasonable expectations. Consent may be provided directly by you, or by your authorized representative, in accordance with applicable law.
disclosure: Making personal information available to a third party, under their control and as used or disclosed by them for their own purposes, independent of services the third party performs for or on behalf of Aryval.
employee: An employee of, or an independent contractor to, Aryval. The inclusion of independent contractors within the definition of “employee” is for convenience of reference only, and should in no manner imply that such independent contractors are our employees within the meaning of employment legislation or are in an employee-employer relationship with us.
Index: Aryval may aggregate and anonymize personal information into an index. This Index will allow Aryval to generate analytics which may be used by schools (as defined in this section) to, among other things, review and consider their recruitment success rate, and other performance analytics.
parent: The parent, legal guardian, or person acting as a parent in the absence of a parent or legal guardian, of a student (as defined in this section) that is under the age of majority in your jurisdiction.
personal information: Information about an identifiable individual.
school: A school that has engaged Aryval’s Services.
student: A student of, or perspective a student of, a school (as defined in this section).
third party: An individual or organization outside of Aryval.
use: The treatment, handling, and management of personal information by and within Aryval or by a third party on behalf of Aryval and with the knowledge and approval of Aryval.
Website: Our website, https://www.aryval.io/.
- Scope and application
This Privacy Policy applies to personal information, in any form, collected, used or disclosed by Aryval through the provision of the Services.
This Privacy Policy does not impose any limits on Aryval’s collection, use or disclosure of the following information:
- information about an individual that is publicly available and is specified by regulation pursuant to PIPEDA;
- personal information that is not collected, used or disclosed, for commercial purposes;
- non-personally identifiable information; and
- the name, title, business address or telephone number of anyone, where the collection, use or disclosure of such information is solely for the purpose of communicating with the person about their employment, business or profession (collectively, “Business Contact Information“).
The application of this Privacy Policy is subject to the requirements and provisions of PIPEDA, and any other applicable legislation or regulation. If you reside in the United States or certain Canadian provinces, such as British Columbia, Alberta or Québec, then the substantially similar privacy law of your jurisdiction will apply to our handling of your personal information, rather than PIPEDA. In that case, reference in this Privacy Policy to PIPEDA will be deemed to include your jurisdiction’s substantially similar privacy law.
- How we collect and use personal information
Except as set out in this Privacy Policy, we only collect personal information about you with your knowledge and consent. Generally, this means we collect personal information directly from you when you use the Services. Occasionally, we may collect personal information from third party sources, such as schools, but only when the third party collects the personal information with your knowledge and consent, or where otherwise authorized by the law.
We may collect and process all or some of the following information about you, from the following sources, and for the following purposes:
| Personal information collected | Collection source | Purpose for collection |
| We may collect the following personal information about you: – contact information, including phone number and email address; – name; – address; and – Postal Code or ZIP Code. We may collect the following personal information about students, from their parents: – name; – date of birth; – the school the student is currently enrolled in; – address; and – name and contact information of parents. | We collect this information from collection forms that are made available on a school’s website. | We may use this information to:provide you with updates on events that you register for or indicate interest in; – provide schools with operational reporting; – assist schools with event planning; – assist schools with enrollment; – assist schools with student management; and – update Aryval’s Index. |
| We may collect the following personal information about you: – contact information, including phone number and email address; – name; – name of your school; and – any other information you may provide when you contact us through our Website. | We collect this information when you fill out the contact form on our Website. | We may use this information to: – provide customer support; – provide you with information that you request from us; – inform you of updates to our Services; and – update Aryval’s Index. |
| We may collect the following personal information about you or students: – any personal information identified in this table; and – any other personal information that a school may disclose to us, in accordance with their privacy practices and policies. | We collect this information from schools you provide your information to, with your knowledge and consent. | We may use this information to fulfill any purpose identified in this table or section. |
In addition to the purposes set out above, we may use your personal information:
- to contact you about schools or Services that may be of interest to you;
- where required by law;
- for any other reason set out in the Privacy Policy; and
- for any other purpose you may consent to.
Further reference to “identified purposes” means the purposes identified in this section of this Privacy Policy. At times, we may engage the assistance of a third party service provider to help us fulfil the identified purposes.
We will indicate the identified purposes to you, orally, electronically or in writing, at or before the time your personal information is collected. Persons collecting personal information may explain the identified purposes or refer individuals to a designated person within Aryval who can explain these identified purposes.
You may withdraw consent for the collection, use and disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. For more information about withdrawing your consent, you may contact Aryval’s Privacy Officer(s).
- Disclosure of personal information
Aryval may disclose your personal information to a school or other third party in the following circumstances:
- to fulfil the identified purposes (including providing personal information to schools, as part of the identified purposes);
- to protect our rights or the rights and safety of our users, or as necessary in the event of a court order, regulatory inquiry or other lawful request;
- in relation to a known or suspected violation of our terms of use, fraud prevention or other unlawful use, by sharing personal information with entities assisting us in an investigation and as may be required by applicable law;
- in the event of a reorganization, merger, sale, assignment, bankruptcy, or similar business change, by transferring your personal information to that re-organized entity or new owner after the sale or reorganization for them to use in accordance with this Privacy Policy; and
- where otherwise required or permitted by law.
We will not disclose more information than is required for the purpose for which the information is being disclosed. We will also, whenever it is reasonable and practicable to do so, enter into confidentiality agreements with third parties with whom we share personal information or otherwise take measures to safeguard your personal information which are consistent with the sensitivity of that personal information.
The personal information you provide in connection to a school will be accessible to that school. Once a school has access to your personal information, it is under their and control and their use of the personal information will be handled in accordance with their privacy practices and policies.
Only our employees who require access for legitimate reasons or whose duties reasonably so require, are granted access to personal information.
We will retain personal information only as long as it remains necessary or relevant for the identified purposes or as required or permitted by law. We maintain reasonable controls, schedules and practices for personal information management retention and destruction. Personal information that is no longer necessary or relevant for the identified purposes, or is required by law to be retained, is destroyed, erased or made anonymous, as appropriate in the circumstances.
- Aryval’s website
Our Website may use various technologies, from time to time, to:
- help us customize your experience on our Website;
- track your use of our Website for advertising, marketing, or promotional purposes;
- help us determine whether you opened an email message from us; or
- gather information to deliver information about products and services we think may be of interest to you.
The type of information we may collect by automated means includes:
- your visiting domain name or IP address;
- the device, browser, operating system type and screen resolution you use;
- information on actions taken at our Website, such as navigation patterns (i.e., pages viewed and downloaded; job postings viewed, etc.) and the date, time, duration and number of times you visited our Website;
- the previous site you visited; and
- the geographical location (such as the country and city of origin) from where you accessed our Website.
This information enables us to:
- customize the services we offer you, to improve our Website;
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Website according to your individual interests;
- speed up your searches;
- recognize you when you return to our Website; and
- show our advertisements on external sites.
When you visit our Website, we may collect certain information by automated means such as through the use of cookies, other automated devices and website tracking tools such as Google Analytics. We use these tools to collect information about how our Website is used. Google Analytics generates statistical and other information about websites by means of cookies stored on users’ computers. Google may collect, transfer, store, and process this information on its servers located in the United States.
- Security of personal information
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to prevent any unauthorized access, disclosure, copying, use, or modification of personal information. Safeguards include securing physical documents and technological measures by way of secure access and encryption. We store all personal information you provide to us on servers which are behind firewalls.
Aryval employees are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to reduce the risk that information will be disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to maintain the integrity of this information and to prevent its being lost or destroyed.
We use measures to protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the personal information and the purposes for which it is to be used.
- Access to your personal information
You may access any personal information that we have concerning you or a student that you are the parent of, and which has been collected, used or disclosed for a commercial purpose, by sending a written request to Aryval’s Privacy Officer. Aryval may advise you in advance if there is a minimal charge to conduct a search of our records and will respond within 30 days, or advise that the request for access is subject to an extension as authorized by PIPEDA.
To protect your privacy, you may be required to provide sufficient identification, in order to permit us to account for the existence, use and disclosure of certain personal information and to authorize access to such information. Any such information will only be used for this purpose.
We may not be able to provide personal information to you if doing so would violate the privacy of a third party or if certain personal information is subject to legal privilege, contains information proprietary to us or a third party, is too costly to retrieve, or cannot be disclosed for other legal reasons. If we are unable to provide access to all or part of your personal information, we will explain our reasons for such a decision.
Where you have been provided with access to your personal information, you will be able to challenge the accuracy and completeness of your personal information and have it amended as appropriate.
Personal information that is disclosed to third parties by us will be subject to the general laws applicable in the jurisdiction in which the third party conducts business. As a result, and in certain limited situations, we may not be legally permitted to account for certain collections, uses or disclosures of personal information. In most circumstances, however, we will provide an account of the collection, use and disclosure of personal information and, where reasonably possible, we will state the source of the personal information. In providing an account of disclosure, we will provide a list of organizations to which we may have disclosed your personal information when it is not possible to provide an actual list.
If we have disclosed your personal information to a school, you may need to contact the school to receive a complete list of organizations to which they may have disclosed your personal information, and to access personal information which is under their control.
- Accuracy of personal information
We make reasonable efforts to ensure that personal information we collect, use or disclose is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. Please be advised, however, that Aryval uses and relies on information from schools, the accuracy of which we cannot control.
If you find any errors in our personal information holdings (including information provided by a school), we should be informed so that we can make the appropriate corrections. Where we are able and it is reasonable to do so, we will convey these corrections to the school when the personal information is not under our control. For personal information that remains in dispute, we will make note in our records of your opinion as to accuracy of the relevant personal information.
- FERPA Compliance
Aryval will comply with all applicable provisions of the Family Educational Rights and Privacy Act (“FERPA“), and agrees that personally identifiable student information, as defined in FERPA, obtained from schools and users in the performance of any agreement will remain under the direct control of the school, will only be used to provide the Services, and will only be disclosed to Aryval’s third party service providers as needed to provide the Services to the schools.
We may create anonymized data from personal information we collect by removing, obfuscating and/or otherwise altering the personal information such that it cannot reasonably be identified. We may use anonymized data for legally permissible purposes.
- Personal information of minors
Aryval’s Services are not intended to be used by individuals under the age of majority, but we may collect personal information about students under the age of majority, from their parents. Before we collect personal information about students under the age of majority, we obtain permission from the verified parent or legal guardian. Subject to reasonable notice and contractual restrictions, parents may contact us at any time to revoke their consent, review the information we have collected from their student, request that we collect no additional information, or request that we delete their student’s information.
If Aryval collects personal information about students under the age of majority from a school, the school and parents agree that the school will be responsible for obtaining verifiable parental consent prior to collecting and disclosing such personal information.
Once personal information is disclosed to a school (regardless of whether the personal information is about a minor), the personal information becomes under the control of the school and, therefore, subject to the school’s privacy practices and policies. For more information about a school’s privacy policies or practices, you may contact that school.
- Challenging compliance with privacy laws
All questions or concerns regarding our privacy practices should be directed to Aryval’s Privacy Officer.
We will investigate all complaints concerning compliance with this Privacy Policy and if a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending our privacy policies and procedures. We will inform you of the outcome of the investigation regarding your complaint.
- Language
You and Aryval have requested and agree that this Privacy Policy and all documents related to this Privacy Policy be drawn up in English. Les parties ont demandé que cette convention ainsi que tous les documents que s’y rattachent soient rédigés en anglais.
- Google reCAPTCHA
We use Google reCAPTCHA to protect our website from spam and abuse. reCAPTCHA analyzes interactions with our site to determine if a visitor is human, and this process may involve collecting information such as IP addresses and user behavior data. The use of reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. - Contact Us
If you have any questions or concerns about this Privacy Policy or about Aryval’s information handling practices, please contact us at: [email protected].
Please also visit the Office of the Privacy Commissioner of Canada’s website at https://www.priv.gc.ca
