NurtureBridge Foundation

(“NurtureBridge“, “we”, “us”, “our”, etc.)

Effective date: October 14, 2025

NurtureBridge is committed to maintaining the privacy of individuals and protecting personal information in its custody or control in accordance with privacy legislation applicable to NurtureBridge.

This Policy describes and summarizes the practices of NurtureBridge and, unless otherwise stated, its subsidiaries and affiliates, if any, from time to time, with respect to our collection, use or disclosure of personal Information.   

This Policy describes the obligations and practices of NurtureBridge under the Personal Information Protection Act (Alberta) (“PIPA“) and, if and as applicable, the Personal Information Protection and Electronic Documents Act (Canada, “PIPEDA“).

Definitions

In this Policy, the following terms have the meanings below:

• Personal information means information about an identifiable individual, which does not include information of an aggregate or anonymous nature where a specific individual or individuals cannot be identified.   Personal Information also does not include business contact information, as long as business contact information is used to contact an individual in their capacity as an employee or official of an organization, and for no other purpose.
• Personal employee information refers to an employee’s personal information reasonably required by us that is collected, used or disclosed for the purposes of establishing, managing or terminating an employment or volunteer relationship, but does not include personal information not related to that relationship.
• Business contact information means an individual’s name and position or title as an official or employee of an organization, as well as their business telephone number, business address, business e-mail, business fax number and other business contact information.

Privacy and our website 

Our policies with respect to our website are as posted on our website and may be revised by us from time to time. 

Sources of Personal Information 

We generally collect, use, and disclose personal information about the following types of individuals:

• Individuals who may voluntarily choose to provide us with personal information (including contact information such as email addresses, phone numbers, mailing or residential address, etc.) for the purposes of our community activities, programs, or services, or to sign up or register for programs, services, or newsletters, or to submit inquiries
• Individuals who provide personal information, which may include demographic information, related to participation in surveys, workshops, or events;
• Employees and independent contractors (where such contractors are individuals) of NurtureBridge for the purposes of establishing, managing and terminating employment and contractor relationships; 
• Directors, officers, management, employees, agents, and contractors of NurtureBridge, including our service providers and partners; 
• Participants in our programs;
• Recipients of any services or goods from us; 
• Donors and sponsors (including billing information, mailing address, email, phone number, etc.) upon contributions to our foundation;
• Other individuals who may voluntarily choose to provide us with personal information for their own personal purposes; and

Notification and consent 

• Subject to this Policy and applicable legislation, we will identify the purposes for collection, use and disclosure in advance of collection, and will notify the individual of the purposes for collection, use or disclosure at or before the time of collection.    
• We will generally obtain consent from the individual at or before the time of collection of personal information.  However, there are a number of exceptions in that in some circumstances, such as with employee personal information, we do not require consent to collect, use or disclose personal information with respect to employees, but may be required to provide notification in advance.  
• In other circumstances, specifically those set out in applicable legislation, the law may not require that we obtain consent or provide notification.  We reserve all our rights to rely on all available statutory exemptions and exceptions.

Exceptions to the requirement for consent

We may collect, use or disclose personal information without consent in circumstances that include but are not limited to the following:

• Where the personal information is personal employee information, and we have given any required notifications. 
• Where a reasonable person would consider that the collection, use or disclosure of the information is clearly in the interests of the individual and consent of the individual cannot be obtained in a timely way, or the individual would not reasonably be expected to withhold consent; 
• Where the collection, use or disclosure of the information is pursuant to a statute or regulation of either Alberta or Canada that authorizes or requires the collection; 
• Where the collection of the information is from a public body and that public body is authorized or required by an enactment of Alberta or Canada to disclose the personal information to us, and we use or disclose it as permitted or required by law; 
• Where the collection, use or disclosure of the information is reasonable for the purposes of an investigation or a legal proceeding, which may include breaches of our policies or illegal activities of third parties that may affect or involve our business;
• Where the information is publicly available; 
• Where the collection, use or disclosure of the information is necessary in order to collect a debt owed to NurtureBridge or for NurtureBridge to repay to an individual money owed by NurtureBridge.

In certain circumstances, where the information may be disclosed without consent, it may also be used without consent.

In addition to the above, the law generally provides that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information.   If you provide personal information to us voluntarily, we will rely on deemed consent and consider that you consent to our collection, use or disclosure of your personal information as necessary to carry out the purposes for which you provided the information.  

Where a new purpose for the use or disclosure of personal information previously collected arises, we will contact the individual in question to obtain any required consent or to provide any required notification for use and/or disclosure for such new purpose or purposes.

Retention and destruction of personal information 

Alberta law allows us, for legal or business purposes, to retain personal information for as long as is reasonable.  Upon expiry of an appropriate retention period, bearing in mind reasonable legal and business requirements, personal information will either be destroyed in a secure manner or made anonymous. 

Should consent to our collection, use, disclosure or retention of personal information be revoked by the individual in question, the law also allows us to continue to retain the information for as long as is reasonable for legal or business purposes.   In the event that revocation of consent may have consequences to the individual concerned, we will advise the individual of the consequences of revoking their consent where it is reasonable in the circumstances to do so.

When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate, up to date, and complete. 

Where practical, we will try to collect personal information directly from you. Where necessary, we will collect personal information from other sources.  When we collect personal information about individuals directly from them, except when their consent to the collection is deemed or has otherwise been previously and lawfully obtained, or is not required, we will tell the individuals the purposes for which the information is collected, and the name of a person who can answer questions about the collection.

Why we collect, use, and disclose personal information

NurtureBridge generally collects, uses, and discloses personal information for reasonable purposes including the following:

• To provide access to programs, services, and resources.
• To establish, maintain, manage and terminate relationships with recipients of our activities, programs, products, and/or services.   
• To respond to inquiries.
• To provide individuals with information with their consent. 
• To process payments and deliver products or services, including processing donations and issuing tax receipts.
• To conduct program evaluations, reporting, and improvement. 
• To communicate updates, newsletters, and community opportunities.
• To establish, maintain, manage and terminate employment or contractor relationships.  
• NurtureBridge is required by applicable laws and regulatory authorities to collect certain information with respect to its shareholders, members, and directors, and that information is used to manage and terminate relationships with shareholders, members, and directors.    
• NurtureBridge is required by applicable laws and regulatory authorities to collect certain information with respect to its donors and to disclose that information as required by law.
• To fulfill our legal obligations, including compliance with legal and funding requirements.
• Personal information from other individuals may be collected when such individuals contact us for a variety of reasons personal to them, after which information provided will then be used and disclosed on a reasonable basis as required to respond.  For example, if you contact us with an inquiry, we will use the information you provide to assist us in responding to you and communicating with you.

Disclosure 

We do not sell, rent, license, or trade your personal information. 

Legal Holds

There are situations where records scheduled for destruction must be preserved and not destroyed. In those cases, NurtureBridge may implement and enforce a “legal hold”. Those situations include audits, investigations, government or regulatory action and actual or potential civil litigation.  In addition, where an individual has requested access to their personal information, it is illegal to destroy that information.  It is therefore our policy to retain all records required for legal purposes for as long as those records, which may include personal information, may be required. 

Outsourcing and Data Hosting Outside of Canada

We may use third party service providers to process or deal with records, documents, data and information on behalf of NurtureBridge, and such records, documents, data and information may include personal information.  In order to protect the confidentiality and security of personal information processed on behalf of NurtureBridge by its service providers, NurtureBridge will use contractual and similar measures with such service providers, including contractual non-disclosure provisions. 

NurtureBridge may use “cloud computing” or “software as a service” third party service providers, and those providers may be either in or outside Canada, and the data housed, hosted and processed by such providers may reside in or outside of Canada, and may include personal information about individuals.  Where consent or notification is legally required, it is our policy to notify individuals about such service providers outside of Canada, and such notification will include the way in which the individual may obtain access to written information about our policies and practices with respect to service providers outside of Canada and the name or tile of a person who can answer any questions about the collection, use, disclosure or storage of personal information by any service providers outside Canada.   

CASL Compliance

Canada has implemented stringent legislation (Generally referred to as Canadian Anti-Spam Legislation, or “CASL“) prohibiting commercial electronic communications without adequate consent, and without an adequate unsubscribe mechanism.  Commercial electronic communications (“CEM’s“) are defined as emails and text messages.  It is the policy of NurtureBridge to not send CEMs without valid legal consent from the recipient, and it is the policy of NurtureBridge to always use the unsubscribe mechanisms prescribed by CASL. 

Security

We recognize our legal obligations to protect the personal information we have gathered about individuals. We have therefore made arrangements to secure against unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.   These arrangements may include physical security measures, network security measures, and organizational measures such as non-disclosure agreements and need-to-know access.

Cookies and our Website

We may also collect non-personally identifiable information automatically through our website such as IP address, browser type, device information, and pages visited (for analytics and site improvement).   Our website may use cookies to help us understand user preferences and improve site performance.  You may adjust your browser settings to refuse cookies.  However, this may affect site functionality.  

Notification of Loss or Unauthorized Access or Disclosure

Where an incident occurs involving the loss of or unauthorized access to or disclosure of personal information under our control, where a reasonable person would consider that there exists a real risk of significant harm to an individual as a result of the loss or unauthorized access or disclosure, we will, without unreasonable delay, provide notice to the Information and Privacy Commissioner for Alberta or the Privacy Commissioner of Canada, as may be applicable, of the incident, including any information required by law at the time to be provided to the Commissioner.  We will notify all affected individuals as required by applicable law, we may elect to immediately do so even if not legally obligated in the event we consider it reasonable in the circumstances.

Requests for Access

Alberta law permits individuals to submit written requests to us to provide them with:

• access to their personal information under the custody or control of NurtureBridge;
• information about the purposes for which their personal information under the custody or control of NurtureBridge has been and is being used; and
• the names of organizations or persons to whom and the circumstances in which personal information has been and is being disclosed by NurtureBridge.

Requests for access are subject to the following:

• Any requests must be in writing.  
• We do not accept such requests or respond to such requests via email.  
• In order to receive a response to such a request, the individual must provide us with sufficient information to locate their record, if any, and to respond to them.  
• We will respond to requests in the time allowed by Alberta law.
• We will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible.  
• All requests may be subject to any fees and disbursements the law permits us to charge.  
• Where appropriate and legally permissible to do so, we may require advance payment of a deposit or the entire cost of responding to a request for access to personal information.

Please note that an individual’s ability to access his or her personal information under our control is not an absolute right.  Alberta law provides that we must not disclose personal information where:

• the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
• the disclosure would reveal personal information about another individual; or
• the disclosure would reveal the identity of an individual who has in confidence provided us with an opinion about another individual and the individual providing the opinion does not consent to the disclosure of his or her identity.

Alberta law also provides that we may choose not to disclose personal information where:

• the personal information is protected by any legal privilege;
• the disclosure of the information would reveal confidential commercial information and it is not unreasonable to withhold that information;
• the personal information was collected by NurtureBridge for an investigation or legal proceeding;
• the disclosure of the personal information might result in similar information no longer being provided to us when it is reasonable that it would be provided;
• the personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act under an agreement, under an enactment, or by a court; or
• the personal information relates to or may be used in the exercise of prosecutorial discretion.

Responses to Requests

Our responses to requests for access to personal information will be in writing, and will confirm:

• whether we are providing all or part of the requested information, 
• whether or not we are allowing access or providing copies, and, 
• if access is being provided, when and how that will be given.  

If access to information or copies are refused by us, we will provide written reasons for such refusal and the section of PIPA (the Personal Information Protection Act, Alberta) on which that refusal is based.  We will also provide the name of an individual at NurtureBridge who can answer questions about the refusal, and particulars of how the requesting individual can ask the Information and Privacy Commissioner of Alberta to review our decision.   In order to receive a response to such a request, the individual must provide us with sufficient information to locate their record, if any, and to respond to them.  

Requests for Correction 

Alberta law permits individuals to submit written requests to us to correct errors or omissions in their personal information that is in our custody or control. If an individual alleges errors or omissions in the personal information in our custody or control, we will either:

• correct the personal information and, if reasonable to do so, and if not contrary to law, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
• decide not to correct the personal information but annotate the personal information that a correction was requested but not made.

Corrections or amendments will rarely, if ever, be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.

Amendment 

NurtureBridge may amend this Policy from time to time as required and without notice, in order to better meet our obligations under the law.  Refer to the date at the beginning of this Policy to learn the date of the last update. 

Contacting Us 

If you have any questions with respect to our policies concerning the collection, use, disclosure or handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, or if you are dissatisfied with how we handle your personal information, please contact our Privacy Officer at:

[email protected]

NurtureBridge Foundation

Edmonton, Alberta

Email: [email protected]

Phone: +1 (587) 778-3766

If you remain dissatisfied after our Privacy Officer has reviewed and responded to your concern, or have other concerns or questions, you have the right at any time to contact the Office of the Information and Privacy Commissioner at:

Office of the Information and Privacy Commissioner 

# 410, 9925 – 109 Street 

Edmonton, Alberta T5K 2J8 

Phone: (780) 422-6860 

Toll Free: 1-888-878-4044 

Fax: (780) 422-5682

Website: https://oipc.ab.ca/