Privacy & Cookies Policy

• Table of Contents

Your privacy is critically important to us. At Propel HQ Inc. we have a few fundamental principles:

• We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.

• We store personal information for only as long as we have a reason to keep it.

• We aim to make it as simple as possible for you to control what information on our website is shared publicly (or kept private), indexed by search engines, and permanently deleted.

• We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Policy Covers

We are Propel HQ Inc. ("Propel," "we," "us," or "our"), and we made it our mission to help the world learn how to swim by providing private lessons that are more affordable, accessible, flexible, and effective. Today, we build technology that helps swim instructors leverage their experience to better serve their communities as recreation entrepreneurs.

This Privacy Policy applies to information that we collect about you when you use our online services (the "Services"), which are made available to you through our website located at www.propelhq.com (the "Site"), or our mobile app (the "App").

By visiting our Site and/or using our App and/or Services, you are agreeing to the terms of this Privacy Policy.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.

We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

As you might expect, we collect and store the information that you provide to us directly. Here are some examples:

• Basic Account Information: We ask for basic information from you in order to set up your account, such as first name, last name, email address, phone number, current city of residence, and password. You may provide us with more information — such as how you heard about our Services — but we don't require that information to create a Propel account.
• Public profile information: If you are registered as an Instructor with Propel, we collect the information that you provide for your public profile. For example, your first name and initial of your last name are part of your public profile, along with a profile photo, description, specific known skills, existence and type of valid training certificates, lesson price, choice of location, and teaching availability.
• Payment and Contact Information: As a user of our Services, you may provide personal and payment information like your name, credit card information, and contact information. We also keep a record of the purchases you've made. If you offer Services as an Instructor with Propel, we will also collect direct deposit information for the purposes of paying out your earnings.
• Swimmer Information: As a user of our Services, you may provide limited information about lesson participants. For example, the first name of each participant may be given to assist the Instructor with lesson planning. It is important you obtain the permission of the participant, or the participant's parent or legal guardian before submitting this data. For more on this, please see Our Policy on Children's Privacy
• Communications with us: You may also provide us with information when you respond to surveys, polls, texts, emails, support questions, reviews, or other communications we send/ask-for in normal operation of our Services. Additionally, when you communicate with us via form, email, phone, review, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services — for example, when you create or make changes to your account.
• Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that users perform, and any preferences that are set. We also collect information about what happens when you use our Services (e.g., page views, support document searches at help.propelhq.com or in the help sidebar, search queries and results, and any errors that occur), along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
• Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, show relevant localized content, or calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
• Stored information: We may access information stored on your device. We access this stored information through your browser permissions and/or device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a really amazing photograph of your teaching skills in action.
• Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Propel uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, engagement, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads on external website (e.g., Facebook or Google ads). For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see the section on Cookies below.

Information We Collect from Other Sources

We may also get information about you from other sources. For example, if you create or log in to your Propel account through another service (like Google) or if you connect your website or account to a social media service (like Twitter), we'll receive information from that service (e.g., your username, basic profile information) via the authorization procedures for that service. The information we receive depends on which services you authorize and what options are available.

As a client using Propel's Services, we may collect information about lesson participants' goals, progress, and lesson plans, mainly to improve the Service.

If you are an Instructor, we may collect extra information about your certifications and customer interactions. For example, if you are registered with a certified training body (e.g., the Red Cross), your information may be available to us through partner programs with those training bodies (e.g., Canadian Red Cross Training Partner program). Additionally, we may collect reviews from your clients to post on your profile.

We may ask users of our Services to provide emergency contact information should anything happen where we need it (and we hope we never do!). It is possible that Propel collected your name and phone number from someone using the Services, however we do not use emergency contact information for anything other than emergencies.

Cookies

What are cookies?

When you visit the Services, we may send one or more “cookies“ – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Site. A cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser.

What cookies do we use?

Our Site uses the following types of cookies for the purposes set out below:

How can I disable cookies?

You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Service may not function properly. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. For example, to set up and maintain your account, host your website, backup and restore your website, provide customer service, process payments and orders, and verify user information.

• To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them create and manage websites more efficiently or make our Services easier to use.

• To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a lesson after receiving a marketing message), and understanding and forecasting user retention.

• To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Propel and others, which may result in us, for example, declining a transaction or terminating Services.

• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.

• To customize the user experience. For example, to personalize your experience by serving you relevant notifications and recommending specific actions to enhance your learning experience, or improve your teaching ability, depending on how you're using Propel.

• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Propel; texting you to verify your payment or to notify you of new lesson bookings; or calling you for customer service issues. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or

(5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on

Sharing Information

How We Share Information

We only share information that is absolutely necessary to complete lessons and provide our Service, with appropriate safeguards on your privacy.

• Partner Facilities and Instructors: We may disclose information about you to our partner facilities and instructors who need the information to provide Services to you. For example, partner facilities and instructors are provided with first name and last name initials so they know who is allowed access on a particular day. Instructors have time-limited access to provided phone numbers in the event they need to get in touch (e.g., first time meetings, running late, or cancellations due to emergency). We require these partners to follow this Privacy Policy for any personal information that we share with them.

• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you or your site. This includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); and other third-party tools that help us manage operations.

• To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Propel, partner facilities, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.

• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.

We have a long-standing policy that we do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.

Information Shared Publicly

Information that you choose to make public will be disclosed publicly. That means information like your public profile, availability, reviews for instructors or facilities, and profile photos are all available to others. For example, if you post a review about an instructor or about a facility, be aware that any content you write in the review will be made public (e.g., swimmer names, dates, situations).

How Long We Keep Information

We will retain your information for as long as your account is active or it is reasonably needed for the purposes set out in How and Why We Use Information unless you request that we remove your personal data as described below in Your Rights. We will only retain your personal data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes). This may include keeping your personal data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Where We Store Information

When you use our services, your data may be sent to the United States and possibly other countries.

We and/or Third Parties we share your information with may transfer, store, use and process your information, including any Personal Information, to countries including the United States. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;

• Request correction or deletion of your personal data;

• Object to our use and processing of your personal data;

• Request that we limit our use and processing of your personal data; and

• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it.

The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);

• Commercial information (your billing information and purchase history, for example);

• Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);

• Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an administrator of a WordPress.com site);

• Geolocation data (such as your location based on your IP address);

• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);

• Professional or employment-related information (for example, your company and team information if you are a Happy Tools user, or information you provide in a job application); and

• Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect in the Information We Collect section above.

We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section.

If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

• Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;

• Request deletion of personal information we collect or maintain;

• Opt out of any sale of personal information; and

• Not receive discriminatory treatment for exercising your rights under the CCPA.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to "How to Reach Us" to, well, find out how to reach us.

When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

Typically, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, except in relation to withdrawing your consent, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Controllers

Propel's Services are provided in Canada only. Propel is the company responsible for processing your personal data and thus is the controller for processing your personal information. Our address is:

Propel HQ Inc.
Care of Propel c/o DMZ
10 Dundas Street East
Suite 600
Toronto ON M5B2G9

How to Reach Us

If you have any questions about our practices or this Privacy & Cookies Policy, please contact us at support@propelhq.com with "PRIVACY POLICY" in the subject line.

Our Policy on Children's Privacy

Protecting the privacy of young children is especially important. Though lessons are suitable for most ages, the Services are not intended for children below 16. If you are under the age of 16, please do not submit any personal information through the Site.

We understand that participants in lessons may be under the age of 16. To assist your instructor with lesson planning, you may optionally provide a participant's first name only after receiving the permission of the participant's parent or legal guardian. The instructor may also collect information about progress or lesson plans. This data is only known to authorized Propel admins and the Instructor for the explicit purpose of enhancing a lesson and providing feedback, and it not used for promotional or marketing purposes.

If you do not wish a participants name to be stored, or permission was not granted, simply enter "n/a", "undisclosed", or similar, or leave the field blank where possible.

Links to Other Websites

This Privacy & Cookies Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Propel and as such we are not responsible for the content, accuracy, or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Your browsing and interaction on any other website, including those that have a link on our Site, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

Changes to Our Privacy & Cookies Policy

We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email. Please refer back to this Privacy Policy on a regular basis.