Privacy Policy

1. Who we are

OS Strategy Ltd. (trading as OnStudy) is a company incorporated in the Province of Alberta, Canada.

• Business incorporation number: 733205900
• Registry ID: 2024240059
• Registered address: 27 Sunrise Crescent SE, Calgary, Alberta T2X 3A1, Canada
• Email: info@onstudy.org
• Phone: +1 408 210 5489

In this policy, "we", "us" and "our" mean OS Strategy Ltd. "You" means anyone who visits this website or contacts us through it.

2. What this policy covers

This policy explains what personal information we collect through en.onstudy.org, why we collect it, who we share it with, and what you can do about it.

We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, as an Alberta organization, Alberta's Personal Information Protection Act (PIPA). Where we send commercial email, we also follow Canada's Anti-Spam Legislation (CASL).

This policy does not cover third-party websites we link to. Those sites have their own policies, and we are not responsible for them.

3. Information we collect

Information you give us. When you fill in a form on this site — a consultation request, a course enquiry, the course finder quiz, or a corporate training request — we collect:

• your name;
• your email address;
• your phone number;
• anything else you choose to write in a free-text field, including your answers to the course finder quiz.

Information we collect automatically. When you browse the site we collect:

• your IP address;
• your browser type, device type and operating system;
• the pages you visit, when, and how long you stay;
• the page or advertisement that brought you here, including campaign tags in the web address (commonly called UTM parameters).

Information about your studies. If you enrol in a course, we also collect the information needed to run it — your account details, your progress through lessons, your submitted assignments, and your correspondence with tutors.

Payment information. If you buy a course, payment is handled by an external payment provider. We receive confirmation that a payment succeeded and a record of what was bought. We do not receive or store your full card number.

We do not intentionally collect sensitive categories of information such as health data, and we ask you not to send such information to us through this site.

4. Why we collect it

We do not use your information to make decisions about you by automated means that produce legal or similarly significant effects.

Additional information for individuals in the EEA and United Kingdom

Where the EU GDPR or UK GDPR applies to our processing, our legal basis depends on why we use the information:

• Performance of a contract, or steps taken at your request before entering into a contract — for enrolment, course delivery, account administration and customer support.
• Our legitimate interests — for service security, fraud prevention, administration and improvement of our services, where those interests are not overridden by your rights and interests.
• Compliance with a legal obligation — where we must retain or disclose information under applicable law.
• Consent — where consent is required, including for certain marketing or non-essential tracking technologies.

Where processing is based on consent, you may withdraw that consent at any time without affecting processing already carried out lawfully.

5. Consent

Consent is one of the grounds we rely on, and it is the ground we use for marketing and for non-essential cookies. You give it when you knowingly submit a form, tick a consent box, or otherwise ask us to do something with your information. For other purposes we rely on the grounds set out in section 4 — performing our agreement with you, our legitimate interests, or a legal obligation.

You can withdraw your consent at any time by writing to info@onstudy.org. Withdrawing consent does not affect anything we did lawfully before you withdrew it, and it may mean we can no longer provide a service you have asked for — for example, we cannot deliver a course without processing your account details.

In limited situations the law allows us to handle information without consent, for example to investigate a breach of an agreement, to detect fraud, or where we are required to disclose information by law.

6. Cookies and analytics

This site uses cookies and similar technologies. Some are necessary to make the site work; others help us understand how it is used.

We use the following analytics services, which set their own cookies and receive information about your visit:

• Google Analytics (Google LLC / Google Ireland Limited) — visit statistics. See Google's privacy policy.
• Yandex Metrica — visit statistics and session behaviour. See Yandex's privacy policy.

You can block or delete cookies in your browser settings. If you do, parts of the site may not work as intended.

7. Who we share information with

We do not sell your personal information, and we do not rent or trade it.

We share it only with service providers who help us run the business, and only to the extent they need it:

• website hosting and technical infrastructure;
• email delivery services, for both individual replies and mailing lists;
• analytics providers named in section 6;
• payment providers, when you buy something;
• our customer relationship and support tools;
• professional advisers such as accountants and lawyers, where genuinely needed.

These providers are required to protect your information and to use it only for the purpose we engaged them for.

We may also disclose information if we are required to by law, by a court, or by a regulator with authority over us, or where necessary to establish or defend a legal claim.

8. Where your information is stored

Our website and its database are hosted on servers located in the Russian Federation. Some of our email, analytics and customer-support providers store and process information in other countries, including the United States and the European Union.

This means your personal information is transferred outside Canada and is stored and processed in countries whose privacy laws differ from Canadian law. While it is held in another country, it may be accessible to the courts, law enforcement and national security authorities of that country under that country's laws.

We take reasonable contractual and technical steps to protect information handled on our behalf. If you would like more detail about our hosting and processing arrangements, or you object to this transfer, please write to info@onstudy.org.

9. Marketing emails

We send commercial email only where you have consented to receive it, or where Canadian anti-spam law otherwise permits it.

Every marketing message we send identifies us, gives our contact details, and contains a working unsubscribe link. Unsubscribing takes effect promptly and you will not need to give a reason.

Unsubscribing from marketing does not stop essential service messages — for example, confirmation of a purchase, or a message about a course you are enrolled in.

10. How long we keep information

• Enquiries that do not become customers: up to 3 years from your last contact with us, so that we can pick up the conversation if you come back.
• Customer and course records: for the duration of the customer relationship and afterwards for as long as reasonably necessary to maintain completion records, handle disputes and comply with legal obligations. Where we keep a permanent record solely to verify that a Certificate of Completion was issued, we limit that record to the information reasonably necessary for verification — the certificate number, the programme, the dates and the name it was issued in.
• Accounting and tax records: for the period required by Canadian law.
• Website analytics: for the period configured with the analytics provider concerned, which we review periodically and limit to what is reasonably necessary for analytics purposes.

When we no longer need information, we delete it or render it anonymous.

11. How we protect information

We use technical and organizational safeguards appropriate to the sensitivity of the information, including encrypted connections (HTTPS) across the site, restricted access to systems on a need-to-know basis, and spam and abuse filtering on our forms.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach occurs that creates a real risk of significant harm to you, we will notify you and the appropriate authorities as required by law.

12. Your rights

Subject to the limits set out in law, you have the right to:

• Ask what we hold about you and receive a copy of it.
• Ask us to correct it if it is inaccurate or incomplete.
• Withdraw your consent to our use of it.
• Ask us to delete it, where we are not required to keep it.
• Unsubscribe from marketing at any time.
• Complain about how we have handled it.

If the EU GDPR or UK GDPR applies to you

You may also have the right, subject to applicable conditions and exceptions, to request erasure or restriction of processing, to object to processing based on legitimate interests, to receive certain personal data in a portable format, and to lodge a complaint with the data protection authority responsible for your place of residence. Where applicable, you also have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects.

Write to info@onstudy.org. We will respond within 30 days, or sooner where applicable law requires it. We may need to verify your identity before acting on a request, and there is no charge for a reasonable request.

13. Children

Our courses and this website are intended for adults. We do not knowingly collect personal information from children under 16. If you believe a child has given us personal information, please contact us and we will delete it.

14. Changes to this policy

We may update this policy from time to time. The effective date at the top shows when the current version took effect. If we make a significant change to how we use your information, we will take reasonable steps to tell you.

15. How to contact us or complain

For any privacy question, request or complaint, contact our Privacy Officer:

• Privacy Officer, OS Strategy Ltd.
• Email: info@onstudy.org
• Post: 27 Sunrise Crescent SE, Calgary, Alberta T2X 3A1, Canada

If you are not satisfied with our response, you may complain to:

• the Office of the Privacy Commissioner of Canada — priv.gc.ca;
• the Office of the Information and Privacy Commissioner of Alberta — oipc.ab.ca;
• if you are in the EEA or the United Kingdom, the data protection authority for your country of residence.