Privacy Policy

Effective Date: January 2026
Last Updated: January 2026

1. Introduction

SOTTILE FILIPPO ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process your personal information when you visit our website, register for programs, or contact us regarding our mindfulness education services.

This Privacy Policy applies to personal information collected through www.sottilemindfulness.ca and related services offered in Canada. By accessing or using our website and services, you agree to the terms outlined in this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

We collect personal information you voluntarily provide when you:

• Fill out contact forms on our website
• Register for mindfulness programs or educational courses
• Request information about our services
• Subscribe to newsletters or communications
• Provide feedback or participate in surveys

This information may include: full name, email address, phone number, mailing address, program preferences, learning format preferences, and any additional information you choose to share in messages or forms.

2.2 Information Collected Automatically

When you visit our website, we may automatically collect certain technical information:

• IP address and device identifier
• Browser type and version
• Operating system
• Pages visited and time spent on pages
• Referring website URL
• General geographic location (country/region level)

This data is collected through server logs and similar technologies to understand how users interact with our website and to improve our services.

3. Legal Basis for Processing (Canada)

Under Canadian privacy laws including the Personal Information Protection and Electronic Documents Act (PIPEDA), we process your personal information based on:

• Your explicit consent (for marketing communications, program enrollment, and contact forms)
• Contractual necessity (to fulfill program registrations and service delivery)
• Legal obligation (to comply with applicable laws and regulations)
• Legitimate interest (to improve our services, prevent fraud, and maintain website security)

4. How We Use Your Information

We use the personal information we collect for the following purposes:

• To process program registrations and deliver educational services
• To respond to your inquiries and provide customer support
• To send program updates, course materials, and educational communications
• To send newsletters and educational content (with your consent)
• To improve our website functionality and user experience
• To analyze website usage patterns and trends
• To prevent fraud and maintain the security of our services
• To comply with legal obligations and regulations

We will not use your personal information for automated decision-making or profiling without your explicit consent.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:

• Program enrollment and educational records: retained for the duration of the program and for 3 years thereafter
• Contact form inquiries: retained for 1 year or until the inquiry is resolved
• Marketing consent: retained until you withdraw consent
• Website analytics: retained for up to 13 months

After the retention period expires, we will securely delete or anonymize your personal information, except where longer retention is required by law.

6. Sharing and Disclosure of Information

We do not sell, rent, or share your personal information with third parties for marketing purposes. We may share your information only in the following circumstances:

• Service Providers: With third-party vendors who provide essential services (email delivery, website hosting, payment processing, analytics) under confidentiality agreements
• Legal Requirements: When required by law, court order, or government authority
• Business Transfers: If our business is acquired or merged, your information may be transferred as part of that transaction
• Consent: With your explicit consent for specific purposes

7. Your Privacy Rights (Canada)

Under Canadian privacy legislation, you have the right to:

• Access your personal information held by us
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information (subject to legal and operational requirements)
• Withdraw consent for marketing communications and newsletters
• Opt out of cookies and tracking technologies
• Request information about how your data is being used

To exercise any of these rights, please contact us at [email protected] with your request. We will respond within 30 days of receipt.

8. Marketing Communications

We may send you educational content, program updates, and newsletters if you have opted in or provided consent. You can unsubscribe from marketing communications at any time by:

• Clicking the unsubscribe link in any email communication
• Updating your preferences on your account
• Emailing us at [email protected] with your request

Please note that even if you opt out of marketing communications, we will continue to send service-related messages regarding your program enrollment or account.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to improve user experience and analyze website usage. Cookies are small files stored on your device that help us remember your preferences and track your activity.

Types of Cookies We Use:

• Essential Cookies: Required for website functionality (form submission, security)
• Analytics Cookies: Help us understand how visitors use our website
• Preference Cookies: Remember your settings and choices

You can control cookies through your browser settings or opt out by using our cookie consent management tool. For more details, see our Cookie Policy.

10. Data Security

We implement appropriate technical, administrative, and physical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data transmission
• Secure password storage with industry-standard hashing
• Limited access to personal information (staff only when necessary)
• Regular security audits and updates
• Secure data backup procedures

However, no transmission over the internet is completely secure. While we do our best to protect your information, we cannot guarantee absolute security. You acknowledge that use of our services is at your own risk.

11. Data Breach Notification

In the event of a data breach that compromises your personal information, we will notify you and relevant authorities as required by Canadian privacy laws. Notification will occur without unreasonable delay and will include information about the nature of the breach and steps you can take to protect yourself.

12. Third-Party Links

Our website may contain links to third-party websites and services. This Privacy Policy applies only to our website. We are not responsible for the privacy practices of external websites, and we encourage you to review their privacy policies before providing personal information.

13. Children's Privacy

Our mindfulness education programs and website are intended for adults. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected information from a minor, we will delete such information and may terminate the minor's access to our services.

14. International Data Transfers

Our company is based in Italy, but we provide services to participants throughout Canada. Your personal information may be stored on servers located in Canada or other jurisdictions. By using our services, you consent to the transfer of your information to jurisdictions outside Canada, which may have different privacy laws than Canada. We will ensure appropriate safeguards are in place for any such transfers.

15. Contact Us and Privacy Requests

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or want to report a privacy concern, please contact us:

16. Privacy Officer

Our organization has designated a Privacy Officer responsible for overseeing privacy compliance and handling privacy inquiries. You can reach our Privacy Officer with any concerns at [email protected].

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our privacy practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated Privacy Policy on our website and updating the "Last Updated" date. Your continued use of our website and services constitutes acceptance of the updated Privacy Policy.

18. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of Italy and the privacy regulations applicable to our services in Canada, including PIPEDA. Any disputes or claims arising from this Privacy Policy or our privacy practices shall be resolved according to the laws of Italy, while ensuring compliance with Canadian privacy legislation.