Privacy Policy

 HS Academy & Services Inc., operating as HS Maritime Academy

HS Academy & Services Inc., operating as HS Maritime Academy ("HS Maritime Academy", the "Academy", "HS", "we", "us", or "our"), is committed to protecting personal information entrusted to us by applicants, participants, students, clients, instructors, assessors, consultants, website visitors, and other individuals who interact with the Academy.

This Privacy Policy describes how we collect, use, disclose, protect, retain, and otherwise manage personal information in connection with our:

• training courses and programs;
• workshops and seminars;
• online, distance, blended, and in-person training;
• examinations and assessments;
• document-review and advisory services;
• maritime certification-related services;
• website and online registration systems;
• learning management and videoconferencing systems;
• customer and participant communications; and
• regulatory, quality-management, administrative, and business activities.

This Policy is intended to reflect applicable privacy requirements, including, where applicable:

• the Act respecting the protection of personal information in the private sector (Québec), as amended, including amendments commonly referred to as Law 25;
• applicable provisions of the Civil Code of Québec;
• the Personal Information Protection and Electronic Documents Act (PIPEDA) where it applies, including certain interprovincial and international commercial activities;
• applicable Canadian electronic-commerce and anti-spam requirements;
• applicable requirements arising under the Canada Shipping Act, 2001, the Marine Personnel Regulations, the Marine Transportation Security Regulations, and related Transport Canada standards, policies, approval conditions, certification procedures, and quality-management requirements;
• applicable requirements implementing Canada's obligations under the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW), 1978, as amended, and the STCW Code; and
• other applicable Canadian or Québec legislation and regulatory requirements.

References in this Policy to Transport Canada, STCW, the International Maritime Organization ("IMO"), or maritime regulatory requirements do not mean that every course or service offered by HS Maritime Academy is approved by Transport Canada or any other authority. The regulatory or approval status of a particular course is stated separately in the applicable course information.

IMO does not itself approve HS Maritime Academy or its courses. Where regulatory approval is required, approval is determined by the competent Canadian authority, including Transport Canada, as applicable.

Nothing in this Policy limits any privacy right that cannot lawfully be waived or limits any obligation imposed on HS Maritime Academy by applicable law.

HS Maritime Academy is responsible for personal information under its control.

Access to personal information within the Academy is limited to personnel, instructors, assessors, contractors, consultants, or authorized representatives who require the information for legitimate duties and who are subject to appropriate confidentiality, contractual, professional, or legal obligations.

The Academy maintains privacy governance practices proportionate to the nature of its operations, which may include policies and procedures governing:

• collection, use, disclosure, retention, and destruction of personal information;
• employee and contractor responsibilities;
• access controls;
• confidentiality incidents;
• participant privacy requests;
• service-provider management;
• privacy complaints;
• privacy impact assessments; and
• secure record management.

The type of information collected depends on the course, service, regulatory requirement, and individual's relationship with the Academy.

We may collect:

• legal name;
• preferred name;
• mailing address;
• email address;
• telephone number;
• date of birth, where necessary;
• emergency contact information, where appropriate;
• nationality or citizenship information where legitimately required for a certification or regulatory process;
• photographs or identity images where reasonably required; and
• government-issued identification information where identity verification is required.

We seek to collect only information reasonably necessary for the identified purpose.

For maritime courses, eligibility assessments, document reviews, certification-related services, or regulated training, we may collect information such as:

• Canadian or foreign Certificates of Competency;
• Certificates of Proficiency;
• STCW training certificates;
• Transport Canada correspondence or assessment letters;
• candidate or seafarer identification information;
• discharge books;
• sea-service records;
• testimonials and sea-service letters;
• training record books;
• examination or assessment history;
• marine medical documentation where legitimately required;
• rank, position, vessel type, employer, and relevant employment history;
• educational qualifications;
• course prerequisites;
• previous maritime training;
• copies of foreign maritime authority documents; and
• other records reasonably necessary to assess eligibility, provide a requested review, administer training, or comply with applicable regulatory requirements.

The Academy's collection or review of a document does not constitute a determination by Transport Canada that the document will be accepted for Canadian certification.

We may collect and maintain:

• course registrations;
• attendance records;
• participation records;
• examination results;
• quizzes and assignments;
• practical assessments;
• competency assessments;
• instructor observations;
• remediation or re-examination records;
• academic-integrity records;
• course completion status;
• certificates issued by the Academy;
• certificate numbers;
• certificate verification records;
• participant feedback; and
• records required under the Academy's quality management system.

For online, distance, or blended training, we may collect information reasonably required to operate and protect the integrity of training, including:

• account and login information;
• attendance and participation logs;
• timestamps;
• learning-management-system activity;
• assessment submissions;
• device or browser information;
• IP address or similar technical information;
• authentication information;
• videoconferencing participation information;
• chat or communication records; and
• other information necessary to verify participation, identity, system security, or assessment integrity.

Where audio, video, photographs, or training sessions are recorded, participants will be informed as appropriate, and consent will be obtained where required by applicable law.

We do not use biometric identification technologies unless their use is specifically disclosed and lawfully authorized.

We may collect:

• billing name and address;
• invoice information;
• payment status;
• transaction amount;
• transaction reference information;
• refunds or adjustments; and
• information reasonably necessary for accounting, taxation, or financial administration.

Payment card information may be processed directly by third-party payment processors. Where this occurs, HS Maritime Academy may receive transaction confirmation and related limited payment information without receiving or retaining all underlying payment-card credentials.

Participants should not send complete credit-card numbers, banking passwords, or other unnecessary financial credentials by ordinary email.

We may retain communications relating to our services, including:

• emails;
• website inquiries;
• telephone or callback records;
• messages submitted through contact forms;
• correspondence relating to registration or certification;
• complaints;
• requests;
• regulatory correspondence; and
• relevant communications through business messaging or social-media platforms.

In limited circumstances, we may need to collect information considered sensitive, including medical, disability, accommodation, or other information necessary to:

• assess a reasonable accommodation request;
• satisfy a safety requirement;
• respond to an emergency;
• satisfy a legitimate regulatory requirement; or
• provide a service requested by the individual.

Sensitive personal information is handled with increased safeguards and, where required by law, express consent.

HS Maritime Academy does not request a Social Insurance Number unless there is a specific lawful requirement for doing so.

Personal information may be collected:

• directly from the individual;
• through online or paper registration forms;
• through our website;
• through course enrollment systems;
• through learning management systems;
• through videoconferencing or online-training platforms;
• through document uploads;
• through email, telephone, messaging, or correspondence;
• through examinations or assessments;
• through attendance and participation systems;
• through payment processors;
• through workshops or event registration;
• from an employer, sponsor, vessel operator, educational institution, instructor, consultant, or other third party where authorized by the individual or otherwise permitted by law;
• from Transport Canada or another regulatory authority where lawfully permitted;
• through website security and technical systems; and
• through cookies and similar technologies as described below.

An organization or individual providing personal information about another person to HS Maritime Academy is responsible for ensuring that it has lawful authority to provide that information and has obtained any consent required by law.

HS Maritime Academy may collect and use personal information for purposes including:

• processing inquiries and registrations;
• communicating with applicants and participants;
• determining whether stated course prerequisites appear to be satisfied;
• creating participant accounts;
• scheduling courses;
• providing training;
• administering workshops;
• providing requested document-review or advisory services;
• administering payments, invoices, cancellations, transfers, or refunds; and
• providing customer support.

• verifying identity;
• tracking attendance;
• administering examinations and assessments;
• verifying participation;
• evaluating training outcomes;
• determining course completion;
• issuing HS Maritime Academy training records or certificates where applicable;
• maintaining certificate records;
• verifying the authenticity of HS-issued certificates where lawfully authorized; and
• preventing certificate fraud, academic misconduct, impersonation, or unauthorized participation.

Where applicable, information may be used to:

• demonstrate compliance with Transport Canada requirements;
• maintain records required for regulated or approved training;
• support course or institutional approval processes;
• respond to audits, inspections, reviews, or monitoring activities;
• support the Academy's Quality Management System;
• demonstrate instructor, assessor, student, attendance, assessment, or training compliance;
• maintain records relating to STCW-based training and assessment;
• communicate with Transport Canada Marine Safety and Security or another competent authority;
• respond to legitimate certificate-verification requests;
• support regulatory certification processes; and
• satisfy applicable recordkeeping or quality-assurance requirements.

Information may also be used to:

• protect participants, staff, systems, and property;
• detect or prevent fraud;
• detect document falsification;
• investigate suspected academic misconduct;
• maintain cybersecurity;
• investigate inappropriate or unauthorized access;
• protect the integrity of examinations and assessments; and
• establish, exercise, or defend legal rights.

We may use information for:

• accounting and taxation;
• corporate recordkeeping;
• contractual administration;
• insurance matters;
• dispute management;
• complaints;
• legal proceedings;
• regulatory inquiries;
• internal audits;
• quality improvement;
• statistical analysis using de-identified or anonymized information where permitted; and
• compliance with applicable legal obligations.

Where consent is required, HS Maritime Academy seeks consent that is appropriate to the nature and sensitivity of the information and the specific purposes involved.

Consent may be express or, where legally permitted, implied from the circumstances.

When applicable law requires express consent, including in relation to certain sensitive information, we will seek express consent.

A request for consent will be presented separately where required by law and in language reasonably designed to allow the individual to understand what is being requested.

An individual may withdraw consent to a use or disclosure that is based on consent, subject to reasonable notice and any legal, regulatory, contractual, quality-management, certification, audit, record-retention, or other lawful restriction.

Withdrawal of consent:

• does not invalidate processing lawfully completed before withdrawal;
• may not require destruction of information that HS is legally or regulatorily required or permitted to retain; and
• may prevent HS from continuing to provide a course, certification-related service, document review, or other service where the information is necessary to provide that service.

HS may also collect, use, retain, or disclose personal information without consent where authorized or required by applicable law.

Individuals may decline to provide information that is optional.

However, certain personal information may be necessary to:

• confirm identity;
• process registration;
• determine course eligibility;
• comply with regulatory requirements;
• administer examinations or assessments;
• verify attendance;
• issue a training certificate;
• complete a requested document review;
• process payment;
• provide an accommodation; or
• comply with law.

If required information is not provided, HS Maritime Academy may be unable to register the individual, provide the requested service, permit participation, complete an assessment, issue a certificate, or perform a requested regulatory or administrative function.

This is not a penalty for withholding consent; it reflects situations where the requested service cannot reasonably or lawfully be performed without the necessary information.

Certain maritime training records may have greater regulatory significance than ordinary commercial records.

Where a course is subject to Transport Canada approval, recognition, monitoring, certification, or quality-management requirements, HS Maritime Academy may retain and process records necessary to demonstrate compliance with the applicable standard.

Such records may include:

• participant identity;
• registration;
• prerequisites;
• attendance;
• assessments;
• examinations;
• practical training;
• instructor or assessor records;
• course completion;
• certificate issuance;
• quality-control information; and
• audit-related information.

These records may be made available to Transport Canada or another legally authorized authority where required or permitted.

The Academy may also preserve relevant records where necessary to investigate suspected certificate fraud, falsification of training records, identity misrepresentation, or other conduct affecting the integrity of maritime training or certification.

Where a participant asks HS Maritime Academy to review maritime credentials or documents, HS may process information such as foreign Certificates of Competency, STCW certificates, sea-service records, Transport Canada correspondence, educational records, or similar documents.

Such a review is provided for the purpose described in the applicable service.

Unless expressly stated otherwise, HS Maritime Academy:

• does not act as Transport Canada;
• does not issue Transport Canada Certificates of Competency or Certificates of Proficiency;
• cannot bind Transport Canada;
• cannot guarantee how Transport Canada will assess a participant's documentation; and
• cannot guarantee regulatory certification or eligibility.

Personal information provided for such a review may be retained to document the service provided, the information relied upon, the advice or feedback provided, and any related legal, contractual, quality-management, or dispute-resolution requirements.

HS Maritime Academy does not sell or rent personal information.

Personal information may be disclosed only as reasonably necessary and as permitted or required by law, including to:

Employees, authorized representatives, instructors, assessors, contractors, or consultants who require access to perform legitimate duties.

Transport Canada Marine Safety and Security, government authorities, regulators, auditors, inspectors, or other bodies where disclosure is authorized, requested under lawful authority, or necessary for an applicable regulatory process.

Third-party providers supporting activities such as:

• website hosting;
• cloud storage;
• learning-management systems;
• videoconferencing;
• online training;
• payment processing;
• accounting;
• electronic communications;
• email delivery;
• cybersecurity;
• IT support;
• document management;
• electronic forms; and
• other business systems.

Such providers are expected to handle information for authorized purposes and subject to appropriate legal, contractual, security, or confidentiality protections.

Where an employer, vessel operator, sponsor, or other organization registers or pays for a participant's training, limited information such as registration, attendance, completion status, or other authorized information may be provided where:

• the participant has been appropriately informed or consented;
• the disclosure is necessary under an applicable arrangement; or
• disclosure is otherwise permitted by law.

Lawyers, accountants, auditors, insurers, or other professional advisers where reasonably necessary to protect legitimate business or legal interests.

Information may be disclosed where required or permitted by law, court order, subpoena, warrant, regulatory authority, investigation, or other lawful process.

HS may also disclose information as permitted by law to prevent or investigate fraud, threats, cybersecurity incidents, document falsification, or other unlawful activity.

Some HS services rely on third-party technologies.

When an individual uses a third-party service, that provider may independently process information under its own privacy terms.

For example, the HS Maritime Academy website currently uses security technology such as Google reCAPTCHA to help protect website forms against spam, abuse, and automated activity. Use of such technology may result in information being processed by the relevant provider under its applicable privacy terms.

Likewise, interactions with external social-media, videoconferencing, payment, or learning platforms may be subject to those providers' own privacy practices.

HS Maritime Academy is not responsible for the independent privacy practices of third-party websites or services that are not under HS's control, but we seek to select and manage service providers in accordance with applicable legal requirements.

Personal information may be stored or processed by HS Maritime Academy or its service providers outside Québec, including elsewhere in Canada or in another country.

Personal information processed outside Québec may be subject to the laws applicable in the jurisdiction where it is processed.

Before communicating personal information outside Québec, or entrusting its collection, use, disclosure, or storage to a provider outside Québec, HS Maritime Academy will conduct a privacy impact assessment where required by applicable law.

Where required, HS will consider factors such as:

• sensitivity of the information;
• purposes of the processing;
• contractual and technical safeguards;
• applicable legal framework; and
• measures available to mitigate identified privacy risks.

Where legally required, appropriate written contractual arrangements will be used.

HS Maritime Academy conducts privacy impact assessments where required by applicable law, including in connection with certain:

• new information systems;
• electronic service-delivery systems;
• major system changes;
• projects involving personal information; and
• communications or processing of personal information outside Québec.

The scope of an assessment is proportionate to the sensitivity, quantity, purpose, distribution, and storage medium of the information involved.

HS Maritime Academy uses reasonable administrative, technical, organizational, and physical measures appropriate to the sensitivity and circumstances of personal information.

Depending on the system and information involved, safeguards may include:

• access restrictions;
• role-based access;
• passwords and authentication controls;
• secure account credentials;
• multi-factor authentication where appropriate and available;
• secure transmission technologies;
• system and device security;
• malware protection;
• backups;
• confidentiality obligations;
• staff and contractor privacy requirements;
• secure cloud services;
• controlled access to physical records;
• secure disposal procedures;
• incident-response procedures; and
• service-provider contractual safeguards.

Access to participant information is limited to those who reasonably require it for their duties.

Despite reasonable safeguards, no electronic transmission, cloud system, email system, or digital storage method can be guaranteed to be absolutely secure.

Accordingly, HS Maritime Academy cannot guarantee absolute security against every possible cyberattack, criminal act, technical failure, or other event beyond reasonable control.

This statement does not limit any responsibility that cannot lawfully be excluded.

Participants are encouraged not to transmit highly sensitive documents through ordinary email or general website contact forms unless requested to do so. Where available, designated secure submission methods should be used.

HS Maritime Academy maintains procedures for responding to actual or suspected confidentiality incidents involving personal information.

Where an incident occurs, HS may:

• investigate the incident;
• take measures to contain it;
• reduce the risk of harm;
• prevent recurrence;
• assess the sensitivity of the information;
• assess potential consequences;
• determine the likelihood of harmful use;
• document the incident; and
• notify affected individuals and the Commission d'accès à l'information du Québec or another authority where required by law.

HS maintains a confidentiality-incident register in accordance with applicable Québec requirements and retains information in that register for the legally required period.

HS Maritime Academy does not intend to retain personal information indefinitely without a legitimate purpose.

Retention periods vary according to:

• the type of information;
• purpose for which it was collected;
• course status;
• regulatory requirements;
• Transport Canada requirements;
• STCW-related quality-management requirements;
• audit requirements;
• tax and accounting obligations;
• contractual obligations;
• limitation periods;
• pending complaints or disputes;
• actual or reasonably anticipated legal proceedings;
• certificate-verification needs; and
• fraud-prevention requirements.

Training, examination, attendance, assessment, certification, instructor, and quality-management records may need to be retained for extended periods where necessary to comply with regulatory requirements or preserve the integrity and verifiability of training records.

Where personal information has been used to make a decision concerning an individual, HS will retain the information for any minimum period required by applicable law.

If information is subject to an access request, complaint, investigation, regulatory review, litigation hold, dispute, or legal proceeding, destruction may be suspended until the matter and applicable retention obligations are concluded.

When the purposes for which personal information was collected or used have been fulfilled and no legal retention requirement applies, HS will destroy the information securely or anonymize it for a serious and legitimate purpose in accordance with applicable law.

HS Maritime Academy takes reasonable measures to ensure that personal information used to make decisions is accurate and current.

Participants and applicants are responsible for providing information and documents that are accurate, complete, authentic, current, and not misleading.

Individuals should inform HS Maritime Academy if relevant personal information changes.

Where HS reasonably suspects that a document, certificate, identity record, sea-service record, or other submitted information has been falsified, altered, fraudulently obtained, or materially misrepresented, HS may investigate and take appropriate action, including disclosure to an authorized regulatory or legal authority where permitted or required by law.

Subject to applicable law, an individual may have the right to:

• request access to personal information HS holds about them;
• request correction of inaccurate, incomplete, or ambiguous information;
• request information concerning the use or disclosure of their personal information;
• withdraw consent where processing depends upon consent;
• request destruction or deletion where applicable and legally available;
• receive qualifying computerized personal information in a structured and commonly used technological format where the statutory portability right applies;
• request cessation of dissemination, de-indexing, or re-indexing where the statutory conditions are satisfied; and
• submit a complaint concerning HS's handling of personal information.

Access and correction requests should normally be made in writing to the Privacy Officer.

HS may reasonably require proof of identity before granting access to personal information.

Where Québec law applies, the person responsible for protection of personal information will respond to a qualifying access or rectification request promptly and generally no later than 30 days after receipt, subject to applicable law.

A request may be refused, restricted, or partially fulfilled where permitted or required by law.

Where a request is refused, HS will provide the information regarding the refusal and available recourse required by applicable law.

A request to withdraw consent or delete information does not automatically require HS Maritime Academy to erase every record concerning an individual.

HS may continue to retain or process information where necessary or permitted for:

• regulatory compliance;
• Transport Canada requirements;
• QMS requirements;
• certification verification;
• accounting or taxation;
• fraud prevention;
• legal obligations;
• contractual obligations;
• audits;
• complaints;
• investigations;
• insurance;
• establishment, exercise, or defence of legal claims; or
• other purposes authorized by law.

Where HS no longer has a lawful or legitimate basis to retain information, it will be destroyed or anonymized in accordance with applicable requirements.

HS Maritime Academy may send information regarding courses, workshops, programs, events, or related services where permitted by law.

Where consent is required for commercial electronic messages, HS seeks the applicable consent and provides an unsubscribe mechanism.

An individual may withdraw from marketing communications without affecting essential administrative, regulatory, safety, transactional, or course-related communications.

HS does not treat consent to necessary course administration as consent to unrelated marketing where separate consent is required.

HS Maritime Academy does not rely solely on general course registration to authorize unrestricted use of a participant's photograph, video, testimonial, or likeness for promotional purposes where separate consent is required.

Where identifiable participant photographs, videos, testimonials, interviews, or similar materials are intended for marketing or public promotional use, separate permission will be obtained as appropriate.

This does not prevent incidental or otherwise legally permitted use where consent is not required by applicable law.

Our website uses or may use cookies and similar technologies for purposes such as:

• essential website operation;
• security;
• fraud and abuse prevention;
• maintaining website functionality;
• remembering preferences;
• measuring website usage; and
• improving website performance.

Where required by applicable law, consent will be obtained before optional or non-essential technologies are activated.

Users may also be able to control cookies through their browser or available website consent settings. Disabling certain essential technologies may affect website functionality.

Third-party technologies may independently collect technical information according to their own privacy practices.

HS Maritime Academy does not currently intend to make decisions producing significant effects concerning participants based exclusively on automated processing without appropriate human involvement.

If HS implements a process in which a decision is based exclusively on automated processing and applicable law requires disclosure, HS will provide the legally required information and opportunity for review.

HS Maritime Academy's maritime professional training is generally directed to individuals who meet the eligibility requirements of the applicable course.

Where HS collects personal information concerning a minor, applicable consent rules will be followed.

Where Québec law requires consent concerning a minor under 14 years of age, consent will be obtained from the person having parental authority or tutor unless collection or use is otherwise authorized by law.

Privacy questions or complaints should first be directed to the Academy's Privacy Officer.

HS will review privacy complaints in accordance with its privacy governance procedures and applicable law.

Individuals may also have the right to submit a complaint or seek recourse before the Commission d'accès à l'information du Québec, the Office of the Privacy Commissioner of Canada, or another competent authority where that authority has jurisdiction.

The person responsible for the protection of personal information at HS Academy & Services Inc. may be contacted through:

Privacy Officer / Person in Charge of the Protection of Personal Information
HS Academy & Services Inc. – HS Maritime Academy

Email: info@hsacademyservices.com

Mailing Address:
50516 PO Box Pro Carre Pelletier CP 50516
Brossard, Québec J4X 2V7
Canada

Telephone:
+1 (438) 540-2833
+1 (514) 677-1944

Website: www.hsacademyservices.com

Individuals submitting privacy requests should clearly identify the nature of their request and provide sufficient information to allow HS to verify identity and locate the relevant information.

Sensitive personal information should not be sent through unsecured channels unless requested.

HS Maritime Academy may revise this Policy to reflect:

• changes in legislation;
• regulatory requirements;
• Transport Canada requirements;
• technology;
• services;
• business practices;
• security practices; or
• privacy guidance.

The current version will be published on our website with its effective or last-updated date.

Where a change materially affects how personal information is collected, used, or disclosed, additional notice or consent will be provided where required by applicable law.

HS Maritime Academy operates in Québec.

A French version of this Privacy Policy shall be made available in accordance with applicable Québec language requirements and on terms of accessibility no less favourable than the English version.

In the event that applicable law requires a particular language version or interpretation to prevail, applicable law governs.

This Privacy Policy describes HS Maritime Academy's privacy practices and is intended to be interpreted consistently with applicable law.

Nothing in this Policy:

• waives a mandatory legal right;
• excludes an obligation that cannot lawfully be excluded;
• guarantees that every cybersecurity risk can be eliminated;
• constitutes a guarantee that a participant will obtain a Transport Canada certificate, approval, endorsement, licence, or regulatory outcome; or
• represents that a course is Transport Canada-approved unless that approval is expressly stated in the applicable official course information.

If a provision of this Policy is inconsistent with a mandatory requirement of applicable law, the mandatory legal requirement will govern to the extent of the inconsistency.

HS Academy & Services Inc.
Operating as HS Maritime Academy
Standards-Driven Maritime Training