SECTION 1 – DEFINITIONS

1.1 “Client” means any individual who registers for, purchases, or participates in Services offered by CGA.

1.2 “Personal Information” means information about an identifiable individual, including but not limited to names, contact details, and information relating to a minor participant.

1.3 “Services” shall have the meaning set out in CGA’s Terms of Service.

1.4 “Platform” means the designated registration system used by CGA, including Amilia SmartRec.

SECTION 2 – COLLECTION OF PERSONAL INFORMATION

2.1 CGA collects Personal Information strictly as necessary for the administration and delivery of Services.

2.2 Such information may include:
(a) Parent/guardian contact information;
(b) Student information including name, date of birth, and medical details;
(c) Media such as photographs and videos (subject to consent);
(d) Account and transaction history.

2.3 CGA limits collection to what is reasonable and necessary.

SECTION 3 – PURPOSE OF USE

3.1 Personal Information is used to:
(a) administer Services;
(b) process payments;
(c) ensure safety;
(d) communicate with Clients; and
(e) improve operations.

3.2 CGA shall only use Personal Information for purposes that a reasonable person would consider appropriate under applicable law.

SECTION 4 – CONSENT

4.1 By registering for Services, the Client provides consent.

4.2 For minors, consent must be provided by a parent or legal guardian.

4.3 Withdrawal of consent may result in suspension or termination of Services without liability to CGA.

SECTION 5 – MEDIA AND IMAGE USE

5.1 Media may be collected during participation.

5.2 Use of such media for marketing purposes requires explicit consent.

5.3 Incidental capture may occur in group settings.

5.4 Withdrawal of consent does not apply retroactively.

SECTION 6 – DISCLOSURE OF PERSONAL INFORMATION

6.1 CGA does not sell Personal Information.

6.2 Personal Information may be disclosed to:
(a) third-party service providers including Amilia SmartRec;
(b) payment processors;
(c) legal authorities where required; and
(d) emergency responders where necessary.

SECTION 7 – SECURITY AND SAFEGUARDS

7.1 CGA implements reasonable administrative and technical safeguards.

7.2 No system is completely secure. CGA shall not be liable for unauthorized access beyond its reasonable control.

SECTION 8 – RETENTION

8.1 Personal Information is retained only as long as necessary for legal and operational purposes.

8.2 CGA may retain information to comply with legal obligations or resolve disputes.

SECTION 9 – ACCESS AND CORRECTION

9.1 Clients may request access to Personal Information.

9.2 CGA may refuse access where permitted by law.

SECTION 10 – PRIVACY BREACHES

10.1 CGA will investigate and respond to privacy breaches in accordance with applicable law.

SECTION 11 – THIRD-PARTY PLATFORMS

11.1 Personal Information may be stored and processed by third-party providers including Amilia SmartRec.

SECTION 12 – WEBSITE AND COOKIES

12.1 CGA may collect technical data such as IP address and browser type for analytics and system functionality.

SECTION 13 – CHILDREN’S PRIVACY

13.1 CGA applies a heightened standard of care when handling Personal Information of minors.

SECTION 14 – AMENDMENTS

14.1 CGA reserves the right to update this Privacy Policy at any time.

SECTION 15 – PRIVACY OFFICER

15.1 Privacy Officer:

Sylvia Chan
Email: contact@creativegeniusacademy.ca

15.2 The Privacy Officer is responsible for compliance and responding to privacy inquiries.

SECTION 16 – COMPLAINTS

16.1 Clients may file complaints with CGA or the Office of the Privacy Commissioner of Canada.

SECTION 17 – GOVERNING LAW

17.1 This Policy is governed by the laws of Ontario and Canada.