Privacy Policy

Our Commitment

Empower Simcoe is committed to protecting your privacy and handling your personal information with care, transparency, and respect.

This Privacy Policy explains what information we collect through the Empower Simcoe Marketplace, why we collect it, how we use it, when it may be shared, and the choices available to you.

We collect only the information necessary to deliver Marketplace services, administer customer accounts, process transactions, communicate with customers, and meet our legal and operational responsibilities.

1. Purpose

The purpose of this Privacy Policy is to explain how Empower Simcoe collects, uses, stores, protects, and discloses personal information obtained through the Marketplace.

This policy supports Empower Simcoe’s commitment to protecting personal information while complying with applicable privacy legislation and recognized privacy best practices.

2. Scope

This Privacy Policy applies to all personal information collected through the Empower Simcoe Marketplace, including information collected when you:
• visit the Marketplace website;
• create or manage a Marketplace account;
• register for programs or services;
• purchase merchandise;
• purchase transportation or other Purchased Services;
• receive Marketplace Credits;
• contact Empower Simcoe regarding Marketplace services; or
• otherwise interact with Marketplace features.

This policy applies only to Marketplace activities. Other Empower Simcoe websites or services may have separate privacy practices.

3. Privacy Principles

Empower Simcoe is committed to:
• collecting only the information necessary to provide Marketplace services;
• being transparent about how information is collected and used;
• protecting personal information through appropriate administrative, technical, and physical safeguards;
• limiting access to information on a need-to-know basis;
• retaining information only as long as reasonably necessary; and
• responding promptly to privacy questions, requests, and concerns.

4. Information We Collect

Depending on how you use the Marketplace, we may collect information including:

Account Information
• name
• address
• telephone number
• email address
• username
• encrypted password

Participant Information

Where you register another individual for a Purchased Service, we may collect information about the participant that is necessary to deliver that service.

This may include:
• participant name
• date of birth
• emergency contact information
• accessibility requirements
• program eligibility information
• other information required to safely deliver services

Only information necessary for the specific program or service will be collected.

Purchase Information

We maintain records relating to Marketplace transactions, including:
• products purchased
• Purchased Services
• registration history
• order history
• Marketplace Credit activity
• invoices
• payment confirmations

Payment Information

Electronic payments are securely processed by approved third-party payment providers.

Empower Simcoe does not store complete payment card numbers within Marketplace systems.

Technical Information

When you visit the Marketplace we may automatically collect information including:
• IP address
• browser type
• operating system
• device information
• pages visited
• referring website
• session information
• cookies and similar technologies

5. How We Use Your Information

Information collected through the Marketplace is used to:
• create and manage customer accounts;
• process purchases and registrations;
• administer Marketplace Credits;
• deliver Purchased Services;
• communicate important program information;
• send receipts and confirmations;
• respond to customer inquiries;
• administer transportation bookings;
• improve Marketplace functionality;
• analyze Marketplace performance;
• maintain Marketplace security;
• prevent fraud;
• comply with legal obligations; and
• support internal reporting and financial reconciliation.

Empower Simcoe does not sell personal information.

6. Communications

We may communicate with customers regarding:
• purchase confirmations;
• registration confirmations;
• schedule changes;
• cancellations;
• Marketplace Credits;
• receipts;
• customer service inquiries;
• important Marketplace updates; and
• other information directly related to Marketplace services.

Where permitted, customers may also receive information about new Marketplace offerings, events, or services.

Customers may unsubscribe from optional promotional communications at any time.

Operational communications relating to active purchases or Marketplace accounts may continue where necessary.

7. Information Sharing

Empower Simcoe only shares personal information where necessary to:
• deliver Purchased Services;
• administer Marketplace operations;
• process payments;
• meet legal obligations;
• protect the safety of participants;
• work with trusted service providers acting on our behalf.
Examples may include:
• payment processors;
• technology providers;
• website hosting providers;
• email delivery services;
• transportation providers;
• program delivery partners;
• government authorities where required by law.

Service providers are expected to protect personal information and use it only for the purposes for which it was provided.

8. Cookies and Analytics

The Marketplace uses cookies and similar technologies to improve functionality and customer experience.

Cookies may be used to:
• remember login sessions;
• maintain shopping carts;
• remember customer preferences;
• analyze website usage;
• improve Marketplace performance;
• support website security.

Customers may manage cookie preferences through their web browser.

Disabling certain cookies may affect Marketplace functionality.

9. Data Retention

Personal information is retained only as long as reasonably necessary to:
• deliver Marketplace services;
• maintain customer records;
• administer Marketplace Credits;
• comply with legal obligations;
• satisfy financial recordkeeping requirements;
• resolve disputes; and
• support operational needs.

When information is no longer required, it will be securely destroyed or anonymized in accordance with Empower Simcoe’s records management practices.

10. Protecting Your Information

Empower Simcoe uses reasonable administrative, technical, and physical safeguards to protect personal information.

Security measures may include:
• encrypted communications;
• secure authentication;
• access controls;
• role-based permissions;
• audit logging;
• software updates;
• malware protection;
• network security controls;
• secure payment processing.

Although reasonable safeguards are used, no electronic system can guarantee absolute security.

11. Your Privacy Rights

Subject to applicable legislation, you may request to:
• access your personal information;
• correct inaccurate information;
• update your contact information;
• withdraw consent where applicable;
• inquire about how your information is being used.

Certain requests may be limited where Empower Simcoe is legally required to retain information or where disclosure would affect the privacy rights of others.

12. Children’s Privacy

Where Marketplace services involve children or dependent individuals, personal information should be provided by a parent, legal guardian, or authorized representative unless otherwise permitted by law.

Only information necessary to administer the Purchased Service will be collected.

13. Third-Party Websites

The Marketplace may contain links to third-party websites or services.

Empower Simcoe is not responsible for the privacy practices or content of external websites.

Customers should review the privacy policies of those organizations before providing personal information.

14. Changes to this Policy

This Privacy Policy may be updated periodically to reflect changes in legislation, Marketplace functionality, operational practices, or organizational requirements.

The current version will always be published through the Marketplace.

Continued use of the Marketplace following publication of an updated Privacy Policy constitutes acceptance of those changes where permitted by law.

15. Related Marketplace Policies

This Privacy Policy should be read together with:
• Marketplace Terms of Use
• Purchased Services Cancellation & Credit Policy
• Shipping, Delivery & Merchandise Returns Policy

16. Contact Information

Questions regarding this Privacy Policy or the handling of personal information may be directed to:
Empower Simcoe
39 Fraser Court
Barrie, Ontario L4N 5J5
Phone: 705-726-9082
Website: marketplace.empowersimcoe.ca

________________________________________

Revision History