Creative Bridges

Last Updated: September 10, 2023
This Privacy Policy (“Policy”) explains the information collection, use, and sharing practices of Creative Bridges organizaion (“CB”, “Creative Bridges,” “we,” “us,” and “our”).

This Policy is incorporated into and part of Creative Bridges Terms of Use (“Terms”) located at https://creativebridges.ca/terms.

Unless otherwise noted on a particular website or service hosted by Creative Bridges, this Policy describes and governs the information collection, use, and sharing practices of Creative Bridges with respect to your use of our websites that link to this Privacy Policy, including: https://creativebridges.ca (collectively, the “Websites”), and the services we provide through our Websites and/or host on our servers, including without limitation the homepage, moodle learning system, calendar scheduler, and the CB Login Services (defined below), (collectively, the Websites, and the services available through them are referred to as the “Services”).

Before you use or submit any information through or in connection with the Services, please carefully review this Privacy Policy. By using any part of the Services, you understand that your information will be collected, used, and disclosed as outlined in this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

1.     Our Principles

Creative Bridges has designed this policy to be consistent with the following principles:

•    Privacy policies should be human readable and easy to find.
•    Data collection, storage, and processing should be simplified as much as possible to enhance security, ensure consistency, and make the practices easy for users to understand.
•   Data practices should meet the reasonable expectations of users.

2.     Information We Collect

We collect information in multiple ways, including when you provide information directly to us; when we passively collect information from you, such as from your browser or device; and from third parties.

Information You Provide Directly to Us

We will collect any information you provide to us. We may collect information from you in a variety of ways, such as when you: (a) create an online account, (b) make a donation or purchase, (c) register for an event, (d) contact us or provide feedback, (e) upload your creative work or images, (f) subscribe to our newsletter. This information may include but is not limited to your name, email address, phone number, mailing address, payment information, photo, geographic location, and your social media handles.  We may also collect additional demographic and other information about you in connection with our conferences and events (e.g., dietary and other preferences), and the provision of this information to us by you is optional.

Information that Is Automatically Collected

Device/Usage Information

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze (a) device information such as IP addresses, location information (by country and city), unique device identifiers, IMEI and TCP/IP address, browser types, browser language, operating system, mobile device carrier information, and (b) information related to the ways in which you interact with the Services, such as referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

Cookies and Other Tracking Technologies

We also collect data about your use of the Services through the use of Internet server logs and cookies. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (a) recognize your computer; (b) store your preferences and settings; and (c) assist with security administrative functions.

 Information from Third Parties

We may also collect information about you or others through third parties. Depending on the source, this information collected from third parties could include name, contact information, demographic information, information to verify identity or trustworthiness, and information for other fraud or safety protection purposes.

3.     How We Use Your Information

We may use the information we collect from and about you to:

•       Fulfill the purposes for which you provided it;
•       Provide and improve the Services, including to develop new features or services, promote CB community collaboration, take steps to secure the Services, and for technical and customer support;
•       Fundraise, accept donations, or process purchases of CB merchandise;
•       Host events and programs;
•       Send you information about your relationship or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed;
•       Process and respond to your inquiries or to request your feedback;
•       Comply with the law and protect the safety, rights, property, or security of Creative Bridges, the Services, our users, and the general public; and
•       Enforce our erms, including to investigate potential violations thereof.

Please note that we may combine information that we collect from you and about you (including automatically collected information) with information we obtain about you from third parties, and use such combined information in accordance with this Privacy Policy.

4.     When We Disclose Your Information

We may disclose and/or share your information under the following circumstances:

•  Legal Compliance and Protection of Creative Bridges and Others. We may disclose your information if required to do so by law or on a good faith belief that such disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons: (a) to comply with legal process; (b) to enforce or apply our Terms and this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) enforce our Charter including the Code of Conduct and policies contained and incorporated therein, (d) to respond to your requests for customer service; and/or (e) to protect the rights, property, or personal safety of Creative Bridges, our agents, our users, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

• Business Transfers. As we continue to develop Creative Bridges, we may change legal structure, which may include the transfer or sale of our assets to a new legal entity. In such transactions, (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed.

• Consent. We may disclose your information to any third parties based on your consent to do so.

5.     Legal Basis for Processing Personal Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose information that can be directly linked to or used to identify you. To the extent those laws apply, our legal grounds for processing such information are as follows:

• To Honor Our Contractual Commitments to You. Much of our processing of information is to meet our contractual obligations to provide services to our users.

• Legitimate Interests. In many cases, we handle information on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, these include:
  • Customer service
  • Marketing, advertising, and fundraising
  • Protecting our users, personnel, and property
  • Managing user accounts
  • Organizing and running events and programs
  • Analyzing and improving our business
  • Managing legal issues

We may also process information for the same legitimate interests of our users and business partners.

• Legal Compliance. We may need to use and disclose information in certain ways to comply with our legal obligations.

• Consent. Where required by law, and in some other cases where legally permissible, we handle information on the basis of consent. Where we handle your information on the basis of consent, you have the right to withdraw your consent; in accordance with applicable law.

6.     Online Analytics

We do not use analytics.

7.     Your Choices and Data Subject Rights

You have various rights with respect to the collection and use of your information through the Services.  Those choices are as follows:

• Email Unsubscribe – You may unsubscribe from our marketing emails at any time by clicking on the “unsubscribe” link at the bottom of each newsletter or by emailing legal@creativebridges.ca with your request.
• Account Preferences – If you have registered for an account with us through our Services, you can update your account information or adjust your email communications preferences by logging into your account and updating your settings.
• EU Data Subject Rights – Individuals in the European Economic Area (“EEA”) and other jurisdictions have certain legal rights (subject to applicable exceptions and limitations) to obtain confirmation of whether we hold certain information about them, to access such information, and to obtain its correction or deletion in appropriate circumstances. You may have the right to object to our handling of your information, restrict our processing of your information, and to withdraw any consent you have provided. To exercise these rights, please email us at legal@creativebridges.ca with the nature of your request. You also have the right to go directly to the relevant supervisory or legal authority, but we encourage you to contact us so that we may resolve your concerns directly as best and as promptly as we can.

8.     International Transfers

Our computer systems are currently based in British Columbia, Canada and the majority of our contractors are based in the United States or Canada. As described above in the “When We Disclose Your Information” section, we may share your information with trusted service providers or business partners in countries other than your country of residence, including the United States, in accordance with applicable law. This means that some of your information may be processed in the United States, which may not offer the same level of protection as the privacy laws of your jurisdiction. By providing us with your information, you acknowledge any such transfer, storage or use.

If we provide any information about you to any third parties information processors located outside of the EEA, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy and other data protection laws to govern the transfers of such data.

9.     Security Measures

We have implemented technical, physical, and organizational security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

10.  Children

The Services are intended for users of ages 8 and up. Written parental consent is required for users under the age of 18. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) or personal data (as defined by the EU GDPR) from children without parental consent we will take reasonable steps to delete it as soon as practicable.

11.  Data Retention

We retain the information we collect for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.

12.  Third-Party Links and Services

The Services may contain links to third-party websites (e.g., social media sites like Facebook and Twitter), third-party plug-ins (e.g., the Facebook “like” button and Twitter “follow” button), and other services. If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Creative Bridges is not responsible for the content or privacy practices of such third party websites or services. The collection, use and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy. We encourage you to read the privacy statements of each and every site you visit.

13.  Changes to this Privacy Policy

We will continue to evaluate this Privacy Policy as we update and expand our Services, and we may make changes to the Privacy Policy accordingly. We will post any changes here and revise the date last updated above. We encourage you to check this page periodically for updates to stay informed on how we collect, use and share your information. If we make material changes to this Privacy Policy, we will provide you with notice as required by law.

14.  Questions About this Privacy Policy

If you have any questions about this Privacy Policy or our privacy practices, you can contact us at: legal@creativebridges.ca.

The Creative Bridges Privacy Policy is dedicated to the public domain under the Creative Commons CC0 Public Domain Dedication. You are free to use and adapt this Privacy Policy and any applicable Supplemental Privacy Policy Terms for your own purposes. However, please keep in mind that this Privacy Policy may not be completely suitable for your situation. Creative Bridges strongly encourages you to seek the advice of your own attorney before repurposing this Privacy Policy on your own site.