VEGA ACADEMIC SERVICES INC. PRIVACY POLICY

This privacy policy (“Privacy Policy”) summarizes what Personal Information we collect when you visit our website, attend VEGA programs, sponsored events such as workshops and seminars, and otherwise use our services in the course of VEGA’s program delivery by participating in online courses, requesting services, completing a questionnaire, making payment or expressing an interest in receiving VEGA publications, news releases, application materials and e-mail bulletins or otherwise provide us with Personal Information. It also explains how we use and disclose this information, and how you may opt-out of some of our practices.

This Privacy Policy applies to Personal Information we collect about users of our Sites, Apps, Wi-Fi hotspots, and other online services, (collectively, our “Services”), as well the Personal Information we otherwise collect about individuals, including current and potential students, visitors to our campuses, prospective students, and others with whom we interact, whether online, via phone, or offline.

The responsibility and authority for adherence and review of this policy resides with the CEO (or designate), with that responsibility shared with VEGA’s Academic Council, Board of Directors, as appropriate.

Service Provider” means any individual, entity (including vendors and marketing and joint venture partners), or agent of an entity, that receives, maintains, processes, or otherwise is permitted to access Protected Information through its provision of services to VEGA (including its affliates) or its students.

Service Provider or Vendor’s compliance with the Privacy Policy is subject to Audit consistent with the terms of their contracts.

All personnel at VEGA, along with all service providers, are required to understand and adhere to the Privacy Policy regarding information and cyber security. VEGA will take appropriate measures to ensure that any service provider accessing Personal Information is capable of complying with relevant data security laws and regulations. Compliance with this Privacy Policy by service providers or vendors will be subject to audits in accordance with the terms outlined in their contracts.

Please read this Privacy Policy carefully to understand our policies and practices for processing and storing data. By interacting us, engaging with our website and otherwise providing your personal information to us, using our services, you accept and consent to our practices and the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Services or submit any Personal Information to us.

VEGA offers education program(s) and courses to its students in Canada who are admitted to our program(s) based on our evaluation of their application, and other information we obtain in respect of it (“Services”). To provide our Services, we collect Personal Information as we describe in this Privacy Policy, and/or in any agreement or application you have with us.

The Personal Information VEGA collects depends on how you interact with us, our Services, or our website. For example, we may collect information, such as:

a) Your full name, and contact information such as your address, phone number, and email address,
b) Information you choose to provide when you communicate with us,
c) Information relating to your race, national or ethnic origin, first language, colour, disability, religion, age, sex, sexual orientation, or marital or family status of the individual;
d) Information relating to your educational, medical, psychiatric, psychological, criminal or employment history or your remuneration or about financial transactions;
e) Contact details including your home address, email address or telephone number;
f) Any identifying number, symbol or other identifier assigned to you; and
g) Other information we are permitted or required to collect by applicable law.

When you visit our website, https://vegaacademy.ca/, we may collect information as described in section
4, “How we Collect Information Automatically when you Visit our Website, and Cookies.”

a) to evaluate the applications for making an admission decision and process tuition payment information;
b) to establish record of students for registration of applicants and following students’ performance in programs and courses;
c) to contact with students, their families, employees, alumni or donors when required;
d) to organize graduation activities for graduating students and their families;
e) for preparation of the Student, Staff and Directories;
f) for preparation of the annual Accreditation and Regulatory Reports;
g) for event notification to students, alumni and donors;
h) to include an individual on VEGA mailing, email, and telephone lists;
i) to recommend particular products and services including counselling services;
j) to understand how visitors interact with our website and our advertising;
k) to improve our website and advertising;
l) to carry out other purposes that are disclosed to you and to which you consent; and
m) to carry out any other purpose permitted or required by law.

When you visit our website, or click one of our online advertisements, we may collect information such as:

• Your domain name
• The time of your visit
• Which pages of our website you visit and what features and links you click or use
• How you interact with communications we send you, such as whether you open an email we send you
• Your Internet Protocol (IP) address
• Your Internet Service Provider (ISP)
• The operating system (Windows, Macintosh, etc.) you use
• The web browser (Netscape, Internet Explorer, etc.) you use
• The identity of the website you visited immediately before coming to our website

This information is used to help us:

a) Manage our website,
b) Diagnose any technical problems,
c) Serve advertising on our website and on third party websites and social media;
d) Track click streams, measure, monitor, and report on website traffic and page views,
e) Determine how visitors arrive at our website and interact with our content, including determining which of our advertisements are the most effective,
f) Remember you if as you navigate through our site, and if you return too it, and
g) Improve the content of our website, and our advertising.

In browsing the internet, you will encounter a technology known as “cookies”. “Cookies” are files or pieces of information that may be stored on a computer/device’s hard drive when an individual visits a web site. Most Internet browsers are initially set to accept cookies. We may also use related technologies, such as web beacons, pixels, other storage technologies, and/or other similar devices. We may use cookies and such related technologies to enable you to use certain website features, improve website functionality, store and customize your preferences, recognize you when you return to our website, and monitor and maintain information about your use of our websites.

We may also work with third party companies to collect information about your use of our website through technologies such as cookies and related technologies so that we may better understand the use of our website. The third parties we work with may include:

• Google, which uses cookies and other technologies to collect and analyze information about the use of our website and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and resources. We may use this for impression reporting and to learn, on an aggregate basis, about the demographics and interests of people who visit our website or click our advertising. You can learn about Google’s practices by visiting https://policies.google.com/technologies/partner-sites and opt out by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.
• From time to time, we may also use Facebook and Twitter tracking pixels and Siteimprove pixel for web optimization. Information collected includes, but is not limited to, data to track frequency of visits, pages visited, web browser used, and city of the web visitor.

We note that Google, Facebook and Twitter own and operate data centers around the world. To find out more about their data center locations and privacy policies, please see the following links:

https://www.google.com/about/datacenters/inside/locations/index.html.
https://www.facebook.com/policy.php
https://twitter.com/en/privacy

You can opt-out of certain of our use of Google Analytics; by using the link we provide in section 4 above.

You may also opt-out of receiving certain behavioral ads by visiting the Digital Advertising Alliance
website at http://youradchoices.ca/.

If you receive commercial email from us, you may opt-out by using the ‘unsubscribe’ tool at the bottom of such messages.

For more assistance, or any questions, please contact us using the information in section 13 below.

We may also disclose or transfer your Personal Information as part of any actual or contemplated merger, sale, transfer of our assets, acquisition, financing, or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.

We may disclose your Personal Information as required under applicable law or in response to legal process (e.g., in response to a subpoena or court order).

We may also use, or disclose your Personal Information to third parties, if we have reason to believe that using or disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us, including if we deem it necessary or advisable for the purpose of collecting any debt you owe us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter; (iv) to respond to claims asserted against us; or () to protect our rights, safety or property.

Lastly, we may disclose your Personal Information for any other purpose to which you consent.

Personal Information may be accessed by persons within our organization, or our third-party service providers, who require such access to carry out the purposes described in this Privacy Policy, and such other purposes as permitted or required by applicable law. Personal Information we collect is managed from our offices in [Toronto].

No security measures can provide absolute protection. As a result, we cannot ensure or warrant the security of any information you provide to us, and you provide Personal Information to us at your own risk. You should always take care how you handle and disclose your Personal Information and should avoid sending Personal Information through insecure email, Social Networks, or other Internet channels.

By providing us with Personal Information, you understand and expressly agree that we may transfer it outside of Canada or your jurisdiction of residence. If you do not agree to the transfer of your Personal Information outside of Canada, do not provide us with Personal Information, or use our Services.

To protect against fraudulent requests for access to your Personal Information, we ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. For example, we may require you to verify your identity before you access your Personal Information.

We reserve the right not to change Personal Information if we disagree that it is incorrect, but we will append your requested alternative information. We may not provide access to Personal Information where permitted or required to deny access by the applicable law, for example, where the information requested would disclose the Personal Information, including opinions, of another individual or if it is subject to solicitor-client or litigation privilege.

Request for access to or correction of your personal information or to withdraw your consent, or any questions or concerns that you may have about the treatment of your personal information or this Privacy Policy, should be directed to the CEO as follows:

Vega Academic Services Inc.
Attention: Taylan Tatli
Title: CEO
Email: ttatli@vega.education