Privacy Policy - Purpose Education Collective Inc.
Last Updated: September 30, 2026
1. Introduction and Scope
Purpose Education Collective Inc. ("PEC," "we," "us" or "our") is committed to protecting the privacy, confidentiality and security of personal information entrusted to us.
PEC is a workforce and staffing organization. We recruit, employ, train and assign part-time and other personnel, including workshop facilitators, learning coaches, student experience coordinators, admissions coordinators and other roles ("PEC Personnel"), to support educational programs and related services operated by our clients ("Clients"). Our Clients include education organizations that work directly with middle school and high school students and their families.
This Privacy Policy ("Policy") explains how PEC collects, uses, discloses, stores, safeguards, retains and destroys personal information, and how responsibility for personal information is shared among PEC, our Clients and the third-party providers we and our Clients rely on.
This Policy applies to personal information about:
applicants and prospective PEC Personnel;
current and former PEC Personnel;
Clients, prospective Clients and business contacts;
students, parents, guardians and families whose information PEC Personnel may access while providing services to Clients;
participants in any program PEC offers directly (see Section 5.6); and
visitors to our websites and people who contact us.
PEC handles personal information in accordance with applicable Canadian federal and provincial privacy legislation, including, where applicable, the Personal Information Protection and Electronic Documents Act ("PIPEDA") and British Columbia's Personal Information Protection Act ("BC PIPA"). Where applicable law imposes requirements different from, or in addition to, those in this Policy, PEC will comply with applicable law.
By applying to PEC, accepting employment or an assignment, engaging PEC's services, or using our websites or services, you acknowledge that you have read and understood this Policy. Where consent is required, we will request it in the manner described in Section 12.
2. Definitions
In this Policy:
"Personal information" means information about an identifiable individual, as defined by applicable privacy law. It does not include business contact information used solely to communicate with an individual in relation to their employment, business or profession, or information that has been anonymized so that an individual can no longer be identified.
"Client" means an organization that engages PEC to supply PEC Personnel or related services.
"Client Information" means personal information that is collected, controlled or made available by a Client, including student and family information, that PEC Personnel access in order to provide services to that Client.
"PEC Personnel" means PEC's employees, contractors, facilitators, coaches, coordinators and other individuals engaged by PEC.
"Service Provider" means a third party that performs services for PEC, such as hosting, payroll, background screening, communications or recruitment technology.
"Recruitment Provider" means a third-party recruitment, applicant-tracking, one-way video interviewing or assessment platform used by PEC.
"Recruitment Data" means information an applicant submits to or generates through a Recruitment Provider, including application materials, assessments, and audio and video recordings of the applicant's image, voice and responses.
"Privacy Incident" means any actual or suspected unauthorized access to, or collection, use, disclosure, loss or destruction of, personal information, including a breach of security safeguards.
"Applicable law" means the privacy, employment, human rights and other laws that apply to a particular activity, individual or jurisdiction.
3. Our Roles: Employer and Service Provider to Clients
PEC plays two different roles, and our responsibilities differ in each.
3.1 When PEC acts for its own purposes. PEC is responsible for personal information it collects for its own purposes, such as recruiting and employing PEC Personnel, managing Client relationships, and operating our websites and business.
3.2 When PEC acts on behalf of a Client. Much of PEC's business involves supplying trained personnel to Clients. PEC Personnel may be given access to Client systems and Client Information where reasonably necessary to perform assigned services. In those circumstances, PEC generally handles Client Information on behalf of the Client and only in accordance with:
PEC's written agreement with the Client;
the Client's authorized instructions;
the Client's privacy, security, safeguarding and technology requirements;
PEC's own privacy, confidentiality, security and employment requirements; and
applicable law.
The Client generally determines why student, family and other Client Information is collected and used, which systems are used, who may access it, how long it is kept, and what notices and consents are required.
3.3 No ownership. PEC does not acquire ownership of, or independent rights to use, Client Information merely because PEC Personnel are authorized to access it.
3.4 Requests about Client Information. If PEC receives an access, correction, deletion or other request, or a complaint, concerning Client Information, PEC may refer it to the responsible Client and assist the Client as appropriate and as required by our agreement and applicable law.
3.5 Access limited to need. Technical ability to access information does not authorize PEC Personnel to access it. Access must relate to an authorized assignment or legitimate business purpose.
4. Accountability and Privacy Officer
PEC is responsible for personal information under its custody or control as required by applicable law, including personal information we transfer to Service Providers for processing on our behalf.
PEC has designated a Privacy Officer who oversees our privacy management program and responds to privacy questions, requests and complaints:
Privacy Officer, Purpose Education Collective Inc. Contact: privacy@purpose-educate.com
50 Lonsdale, North Vancouver, BC V7M 2E6
PEC maintains policies, procedures, training and safeguards designed to support responsible handling of personal information by PEC Personnel and Service Providers, and reviews them periodically.
5. Personal Information We Collect
The information PEC collects or handles depends on your relationship with us. We limit collection to what is reasonably necessary for the purposes identified in this Policy.
5.1 Applicants and prospective PEC Personnel
name, contact information and location;
résumé, cover letter and application responses;
employment and education history, qualifications, skills and certifications;
interview notes and assessment results;
written, audio and video responses, including one-way video interview recordings (see Section 6);
references and reference-check information;
availability, work preferences and eligibility to work in Canada;
background, criminal record or vulnerable sector check information, where permitted by law and relevant to the role;
information needed to assess suitability for employment or a specific Client assignment;
accommodation information you choose to provide; and
communications with PEC about your application.
5.2 PEC Personnel (employees and contractors)
identification, contact and emergency contact information;
payroll, banking, tax and benefits information, including Social Insurance Number where required by law;
employment agreements, compensation and employment records;
scheduling, availability, attendance and time records;
training, certifications and professional development;
performance, conduct and feedback records;
Client assignment information;
workplace communications and use of PEC and Client systems;
account, device, security and access records;
investigation, complaint or incident records where applicable;
health or accommodation information only where necessary and permitted by law; and
other information reasonably required to establish, manage or end the employment or contract relationship.
5.3 Clients and business contacts
name, position, organization and professional contact information;
communications and meeting information;
service requirements, contracts, billing and transaction information; and
other information needed to establish and manage the business relationship.
5.4 Students, parents, guardians and families (Client Information)
PEC does not generally maintain its own student databases. PEC Personnel may access student and family information through systems selected, authorized or managed by a Client where necessary to provide services. Depending on the Client and program, this may include:
student name, age, grade, school, cohort and program information;
student and parent or guardian contact information;
attendance and participation;
assignments, submissions, projects, goals and reflections;
learning progress and performance information;
facilitator or coach feedback and observations;
admissions and enrolment information;
communications;
session recordings;
accommodation or support information where necessary;
safeguarding, conduct or incident information where necessary and appropriate; and
other information made available by the Client and reasonably required for program delivery.
5.5 Website visitors and inquiries
name, email address, telephone number and organization;
information submitted through forms or inquiries;
IP address, browser, device and operating system information;
pages viewed, links clicked and other usage information; and
information collected through cookies and similar technologies (see Section 21).
5.6 Direct Programs (applies only where PEC itself offers a program to students or families)
Where PEC offers a program directly to students or families rather than through a Client (a "Direct Program"), PEC may collect:
from parents or guardians: name, email address, postal code, optional photo or avatar, account credentials, and information about the student they register;
about students: name, email address, grade, school, username and optional avatar or photo, collected through the parent or guardian;
program activity ("Performance Data"): content completed, responses to questions, progress through the curriculum and time spent on activities, used to personalize the student's learning and to report progress to the linked parent or guardian; and
payment information, which is processed and stored by our third-party payment processor. PEC does not store full credit card numbers.
PEC does not permit third-party advertising in student-directed areas of any Direct Program and does not allow third parties to collect student information for targeted advertising.
6. Third-Party Recruitment Platforms and One-Way Video Interviews
6.1 Use of Recruitment Providers. PEC uses third-party Recruitment Providers to administer parts of our recruitment process, including online applications, applicant tracking, assessments and one-way (asynchronous) video interviews. In a one-way video interview, the applicant records answers to preset questions, and PEC reviews the recording later.
6.2 Notice before you submit. Before an applicant is asked to complete a one-way video interview, PEC will provide a separate Candidate Acknowledgment that identifies the Recruitment Provider, explains how Recruitment Data is handled, and describes the risks set out in this Section. Applicants are asked to confirm that acknowledgment before proceeding.
6.3 Alternatives. Completing a video interview is not the only way to be considered. Applicants who prefer not to use the video tool, or who need an accommodation, may contact careers@purpose-educate.com to request an alternative, such as a live interview or written responses. Choosing an alternative will not, by itself, disadvantage an applicant.
6.4 What applicants acknowledge. Applicants who choose to submit Recruitment Data after receiving notice acknowledge that:
PEC uses third-party technology to administer portions of recruitment;
Recruitment Data is transmitted to, hosted, stored and processed on systems operated by the Recruitment Provider and its own service providers, not on systems PEC operates;
Recruitment Data may be stored or processed outside the applicant's province or outside Canada, including in the United States and the EU, and may be subject to the laws and lawful access requirements of those jurisdictions;
PEC and its authorized representatives may access Recruitment Data for legitimate recruitment, assessment, hiring, workforce planning, compliance and related purposes;
the Recruitment Provider has its own terms of use and privacy policy, which also govern the applicant's account and use of its platform;
electronic transmission and third-party storage involve inherent risks, including unauthorized access, cyberattacks, software vulnerabilities, technical failures and human error; and
no electronic system can be guaranteed to be completely secure.
6.5 What PEC does. For Recruitment Providers that PEC selects, PEC takes reasonable measures appropriate to the sensitivity of the information, including reviewing the provider's privacy and security practices, using contractual protections that require the provider to protect Recruitment Data and use it only to provide services to PEC, limiting access within PEC to people involved in recruitment, and setting retention periods.
6.6 Automated tools and AI. If a Recruitment Provider offers automated or AI-based features, such as transcription, scoring, ranking or analysis of responses, PEC will disclose in the job posting or the Candidate Acknowledgment whether those features are used to screen, assess or select applicants. PEC does not make hiring decisions based solely on automated processing; a PEC representative reviews applications before a hiring decision is made. PEC does not use tools that infer emotions, personality or protected characteristics from an applicant's face or voice.
6.7 Keep your recording focused. Applicants should record in a private setting, avoid showing other people, identification documents or personal items, and share only information relevant to the role. Please do not volunteer health, family status or other sensitive information unless you are requesting an accommodation.
6.8 Limits of PEC's responsibility. The Recruitment Provider is an independent company. PEC does not own, operate, host or control the Provider's infrastructure, software, security architecture, personnel, subprocessors, availability or independent conduct, and cannot inspect or direct its day-to-day security operations. To the maximum extent permitted by applicable law:
PEC makes no representation, warranty or guarantee that a Recruitment Provider's systems will be secure, uninterrupted, error-free or free from cybersecurity incidents, unauthorized access, malicious activity, technical failures or data loss;
PEC is not responsible or liable for any loss, damage, cost or claim arising from a Privacy Incident, outage, defect, act or omission within or by a Recruitment Provider or its subprocessors, except to the extent caused by PEC's own failure to meet an obligation that applicable law places on PEC;
PEC is not responsible for the Provider's own collection, use or disclosure of information for its own purposes under its own terms and privacy policy; and
PEC is not responsible for incidents caused by an applicant's own devices, networks, accounts or credentials, or by information an applicant chooses to include in a submission beyond what was requested.
If a Recruitment Provider notifies PEC of a Privacy Incident affecting applicants, PEC will cooperate with the provider, assess the incident and make or support any notifications required by applicable law (see Section 18).
6.9 Nothing excludes non-excludable obligations. Nothing in this Section limits any right an applicant has under applicable law, or excludes any obligation or liability that applicable law does not permit PEC to exclude.
6.10 Retention and deletion. Retention of, and requests to delete, Recruitment Data are described in Section 19.
6.11 Applicant responsibilities. Applicants who use a Recruitment Provider are responsible for:
reading and deciding whether to accept the Provider's terms of use and privacy policy;
keeping their own devices, internet connection, email account and platform credentials secure;
submitting only information requested for the application, and not including information about other people; and
telling PEC promptly if they believe their account or submission has been compromised.
6.12 Your relationship with the Provider. When you create an account with or submit information through a Recruitment Provider, you enter into your own agreement with that Provider under its terms. Questions or claims about the Provider's own systems, security or practices may be raised directly with the Provider, and PEC will reasonably assist where the information relates to your PEC application.
7. How We Collect Information
PEC may collect personal information:
directly from you, including through applications, forms, interviews, email and other communications;
from parents or guardians, where appropriate;
from Clients, including through Client-authorized systems;
through Recruitment Providers and other technology platforms;
from references you identify and from background-screening providers, with your consent where required;
through our websites, cookies and similar technologies;
during training, meetings, program sessions and other activities; and
from other sources where permitted by law.
If you give PEC personal information about another person, such as a reference or emergency contact, you confirm that you have the authority to do so and that the person is aware of how it will be used.
8. How We Use Personal Information
PEC uses personal information only for purposes a reasonable person would consider appropriate in the circumstances, including:
Recruitment and employment
recruiting, screening and evaluating candidates, including reviewing recorded video responses;
verifying qualifications, references and eligibility to work;
conducting background or vulnerable sector checks where permitted and relevant;
making hiring and Client-assignment decisions;
administering employment, payroll, benefits, tax and statutory obligations;
scheduling, training, supervision and performance management;
workplace investigations, safety and security; and
providing accommodation and meeting human rights obligations.
Client services
establishing and managing Client relationships and understanding Client requirements;
assigning PEC Personnel and delivering contracted services;
supporting educational, admissions and student experience programs;
monitoring service quality; and
investigating complaints and incidents and meeting contractual obligations.
Direct Programs (where applicable)
creating and managing parent and student accounts;
personalizing a student's learning and reporting progress to the linked parent or guardian; and
processing payments and communicating about accounts and services.
Business operations
operating, securing and improving PEC systems and services;
processing payments and keeping business records;
preventing fraud and misuse;
managing legal claims, audits, insurance and compliance; and
protecting PEC, Clients, PEC Personnel, students and others.
Aggregated and de-identified information. PEC may create aggregated or de-identified information that no longer identifies any individual and use it to analyze and improve our services. We will not attempt to re-identify it.
PEC will not use personal information for a materially different purpose without consent unless permitted or required by law.
9. Children and Young People
PEC recognizes that information about children and young people requires heightened protection.
9.1 Client programs. Where PEC Personnel handle student information on behalf of a Client, the Client is responsible for establishing the authority, notices and consents its program requires, including parent or guardian involvement where required. PEC limits PEC Personnel's access to the student information reasonably necessary for their assigned responsibilities.
9.2 Direct Programs. Student accounts in a Direct Program are created only by a parent or legal guardian aged 18 or older, who consents on the student's behalf where consent is required. Students do not register themselves. We collect only the student information needed to operate the program, and share a student's information only with the parent or guardian linked to that student's account and as otherwise described in this Policy.
9.3 Commitments. PEC:
does not sell, rent or trade student personal information;
does not use student information for targeted advertising or permit third-party advertising in student-directed services;
does not use student information obtained through Client programs for PEC marketing; and
does not use student information to build profiles unrelated to the educational services provided.
9.4 PEC Personnel conduct. PEC Personnel must communicate with students only through channels authorized by PEC and the Client, must not contact students through personal accounts, phones or social media, and must follow applicable PEC and Client safeguarding, privacy, technology and conduct requirements.
9.5 Safeguarding. PEC may collect, use or disclose information where necessary to protect a child's safety or to comply with child-protection reporting obligations under applicable law.
10. Online Sessions and Recordings
Educational, coaching, training, admissions and program sessions delivered by PEC Personnel may be audio or video recorded. Recordings may be used for:
participant and student safety and safeguarding;
quality assurance and service monitoring;
training and coaching of PEC Personnel;
investigating incidents or complaints;
verifying program delivery; and
other purposes disclosed to participants and authorized by law.
Where a Client decides that sessions will be recorded, the Client is responsible for providing required notices and establishing consent or other lawful authority, unless PEC has agreed otherwise in writing. PEC may rely on the Client's representation that it has done so unless circumstances reasonably indicate otherwise.
PEC Personnel must not record sessions on personal devices, personal accounts or unauthorized applications. Access to recordings is restricted to authorized individuals, and recordings are retained only as long as required by the Client, our agreements and applicable law.
PEC may record internal training sessions and meetings for PEC Personnel and will tell participants when a session is being recorded.
11. Artificial Intelligence and Automated Tools
PEC may authorize AI, machine-learning or automated tools for purposes such as lesson and program planning, preparing educational materials, drafting, summarization, administrative assistance and supporting feedback.
PEC Personnel may use only AI systems authorized by PEC and, where applicable, by the Client.
Personal, confidential, Client, student, family or employee information must not be entered into an AI system unless that system and that use have been authorized.
Where practicable, information is anonymized, de-identified or minimized before it is submitted to an AI system.
PEC Personnel must not use personal or unauthorized public AI accounts to process Client or student information.
AI-generated output may contain errors or omissions. A person must review it before it is relied on for a decision or material that may affect an individual, or for a material business, employment or educational purpose.
PEC does not make decisions about individuals based solely on automated processing without human review. Where applicable law requires notice of automated decision-making, PEC will provide it.
To the maximum extent permitted by law, PEC does not warrant the accuracy, completeness or reliability of AI-generated output.
12. Consent and Other Legal Authority
PEC obtains consent where applicable law requires it. The form of consent (express or implied) depends on the sensitivity of the information, your reasonable expectations, the purpose, and your age and capacity. We seek express consent for sensitive information, such as background checks, where required.
Employee information. Where permitted by applicable law, PEC may collect, use and disclose personal information reasonably required to establish, manage or end an employment relationship without consent, after notifying the individual of the purposes.
Other legal authority. PEC may also collect, use or disclose personal information without consent where permitted or required by law.
Client authority. Where PEC handles Client Information, PEC may rely on the Client's representation that it has the authority to provide the information and to authorize PEC Personnel's access, subject to applicable law and our agreements.
Withdrawal. You may generally withdraw consent on reasonable notice, subject to legal and contractual restrictions. Withdrawal may affect PEC's ability to consider an application, continue employment, or provide a service. It does not affect processing that took place before withdrawal, or information PEC is permitted or required by law to keep.
13. Disclosure and Sharing
PEC does not sell, rent or trade personal information. We disclose personal information only where reasonably necessary, including to:
Clients, for example an assigned PEC Personnel member's name, qualifications, schedule and relevant screening status;
Service Providers, such as recruitment, payroll, benefits, background screening, IT, cloud hosting, communications, learning and payment providers;
parents or guardians linked to a student's account in a Direct Program;
professional advisers, insurers and auditors;
government, regulatory, judicial or law-enforcement authorities, where permitted or required by law;
parties to an actual or proposed corporate transaction (see Section 22); and
others, with your consent or at your direction.
PEC shares with Service Providers only the information they need to perform their services, and requires them by contract or other means to protect it and not use it for their own purposes.
14. Third-Party Platforms and Service Providers
PEC and its Clients use third-party technology for recruitment, email, productivity, document management, communications, video conferencing, learning management, electronic forms, background screening, payroll, payments, customer relationship management, hosting, analytics, security, AI and automation. Examples may include Google Workspace, Slack, Zoom and Stripe. The platforms we use may change over time.
14.1 How PEC selects providers. For providers PEC selects, we consider the sensitivity of the information, the provider's privacy and security practices, processing locations, subprocessors, contractual protections, breach-notification commitments and retention and deletion capabilities.
14.2 Client-controlled platforms. Where a Client purchases, selects, configures, administers or controls a platform used by PEC Personnel, the Client is responsible for that platform's selection, configuration, security settings, notices and retention, except to the extent PEC has expressly accepted responsibility in writing or applicable law places it on PEC.
14.3 Independent practices. Third-party providers operate under their own terms and privacy policies. PEC does not control their independent practices except to the extent of PEC's contractual rights. When you create your own account with a third-party platform, that provider's terms and privacy policy also apply to you.
15. Processing and Storage Outside Canada
PEC, its Clients and their Service Providers may use infrastructure, providers or personnel located outside your province or outside Canada, including in the United States and the EU. Personal information may therefore be transferred to, stored in, or accessed from another jurisdiction, where it may be subject to that jurisdiction's laws and to lawful access by its courts, governments, regulators and law-enforcement or national security authorities.
Where PEC selects a provider that processes information outside Canada, PEC takes reasonable measures appropriate to the circumstances, including contractual protections, to protect that information. Where a Client selects and controls a provider, the Client is responsible for that choice and the related notices and safeguards, subject to any responsibility applicable law or contract independently places on PEC.
If you have questions about where your information is stored, contact the Privacy Officer.
16. Security Safeguards
PEC maintains administrative, technical, contractual and physical safeguards appropriate to the sensitivity of the information under its control, which may include:
confidentiality agreements and privacy and security training for PEC Personnel;
role-based, need-to-know access;
authentication controls, strong passwords and multi-factor authentication;
encryption in transit and, where appropriate, at rest;
device and system security, and restrictions on downloads, local storage, personal accounts and unauthorized applications;
logging and monitoring where appropriate;
vendor due diligence and contractual controls;
incident-response procedures; and
secure retention and destruction practices.
Your part. You can help protect your information by using strong, unique passwords, keeping your devices secure, and signing out of accounts when finished. Tell us promptly if you believe your account or information has been compromised.
PEC takes reasonable measures to protect personal information, but no internet transmission, electronic communication, cloud service, software platform or storage system can be guaranteed to be completely secure, uninterrupted or error-free.
17. PEC Personnel Confidentiality Obligations
PEC Personnel must protect confidential and personal information they encounter. Unless authorized, PEC Personnel must not:
access records unrelated to their assigned responsibilities;
copy Client or student information to personal accounts, devices or storage;
share login credentials;
disclose information to unauthorized people;
communicate with students through unauthorized channels;
record sessions independently;
enter information into unauthorized AI systems;
retain Client information after an assignment ends or beyond legitimate requirements; or
use personal information for personal, commercial or unrelated purposes.
At the end of an assignment or employment, PEC Personnel must return or securely delete Client and PEC information in their possession, and access will be removed.
These obligations continue after employment or assignment ends. A breach may result in discipline up to and including termination and may carry legal or regulatory consequences. PEC Personnel who fail to follow these requirements act outside the scope of their authorization.
18. Privacy Breaches and Incidents
PEC maintains procedures to identify, report, contain, investigate and respond to Privacy Incidents.
18.1 Reporting by PEC Personnel. PEC Personnel must immediately report to the Privacy Officer any suspected unauthorized access, use or disclosure; lost or stolen devices or records; misdirected communications; compromised accounts; unauthorized recordings; improper AI use; or other suspected Privacy Incident.
18.2 PEC's response. PEC will take reasonable steps to contain the incident, assess the risk of harm, and make any notifications to affected individuals, regulators or others that applicable law requires. PEC keeps records of breaches as required by law.
18.3 Incidents involving Clients or providers. Where an incident involves Client Information, PEC will notify and cooperate with the Client as required by our agreement and applicable law; the Client may be responsible for notifying affected students and families. Where an incident occurs within a Service Provider's or Recruitment Provider's systems, PEC will seek information from the provider, require its cooperation as provided in our agreement, and make or support legally required notifications.
19. Retention and Destruction
PEC keeps personal information only as long as reasonably necessary for the purposes identified, or as required for legal, employment, contractual, regulatory, insurance, accounting, dispute-resolution or operational reasons. When information is no longer required, PEC securely deletes, destroys or anonymizes it. Where information is stored in a Client-controlled system, the Client's retention rules apply.
19.1 Typical retention periods:
Category
Typical retention
Video interviews and Recruitment Data – unsuccessful applicants
Up to 6 months after the recruitment round closes, unless the applicant asks to be considered for future roles or a longer period is required by law
Recruitment Data – hired applicants
Moved to the employee file; video recordings deleted once hiring is complete
Employee and contractor records
Duration of the relationship plus the period required by tax, employment and limitation laws
Background and vulnerable sector check results
Only as long as needed to confirm suitability and meet Client or legal requirements
Client and business records
Duration of the relationship plus the period required for accounting and legal purposes
Direct Program accounts
While the account is active; PEC may delete inactive accounts after a period of inactivity
19.2 Deleting Recruitment Data. Applicants may ask PEC to delete their video responses and other Recruitment Data at any time by contacting the Privacy Officer at privacy@purpose-educate.com. Withdrawing a video will end consideration for that application unless an alternative is arranged. Where no lawful reason requires PEC to keep the information, PEC will delete information under its control and instruct the Recruitment Provider to delete information it processes on PEC's behalf.
19.3 When PEC may retain information. PEC may keep information where permitted or required to meet employment or regulatory requirements, respond to complaints or access requests, establish or defend legal rights, prevent fraud or misuse, or comply with other legal obligations. Information that has been used to make a decision about an individual is kept long enough for that individual to access it, as required by applicable law.
19.4 Backups. Deleting information from active systems may not immediately delete it from encrypted backups, disaster-recovery systems or archives where immediate deletion is not technically practicable. That information remains protected and is deleted in the normal backup cycle.
20. Your Rights: Access, Correction, Deletion and Withdrawal
Subject to applicable law, you may:
request access to personal information about you in PEC's custody or control, and information about how it has been used and disclosed;
request correction of information that is inaccurate or incomplete;
request deletion of information PEC no longer needs (see Section 19);
withdraw consent (see Section 12); and
ask questions or make a complaint (see Section 25).
Parents and guardians in a Direct Program may request access to, correction of, or deletion of their child's information, or ask PEC to stop collecting it. This may require closing the account.
Send requests to the Privacy Officer at privacy@purpose-educate.com. PEC will verify the identity and authority of the person making the request and respond within the time required by applicable law. Access may be limited or refused where permitted or required by law, and we will explain why where the law requires it.
Where a request concerns Client Information, PEC may refer it to the responsible Client and assist the Client as appropriate.
Accuracy. PEC takes reasonable steps to keep information accurate, complete and current for its purposes. Please provide accurate information and tell us about changes.
21. Cookies, Website and Marketing
Cookies. PEC websites use cookies, pixel tags and similar technologies to operate the site, remember preferences, maintain security, diagnose issues, measure performance and understand usage, including through analytics tools such as Google Analytics. You can control cookies through your browser settings; disabling some may affect site functionality. Where required by law, PEC will offer choices about non-essential technologies.
Advertising. PEC may use advertising partners to show PEC ads to adults who visit areas of our websites that are not directed to students. PEC does not permit third parties to collect information from student-directed services for targeted advertising.
Marketing messages. Where permitted by law, including Canada's anti-spam legislation, PEC may send business contacts, applicants who opt in, and parents in Direct Programs information about PEC services, opportunities and events. You can unsubscribe at any time using the link in the message or by contacting us. PEC does not use student information obtained through Client programs for marketing.
22. Business Transactions, Legal Requirements and Safety
Business transactions. PEC may disclose or transfer personal information, as permitted by law, in connection with a proposed or completed financing, investment, reorganization, merger, acquisition or sale of all or part of its business. Parties receiving information will be required to protect it and use it only for purposes related to the transaction, and any acquirer will be required to handle it consistently with this Policy.
Legal requirements and safety. PEC may collect, use, preserve or disclose personal information where permitted or required by law, including to:
comply with legal process and respond to lawful requests from authorities;
investigate fraud, misconduct or breaches of agreements or policies;
establish, exercise or defend legal rights;
protect PEC systems and information;
respond to emergencies that threaten someone's life, health or security; and
protect the safety of students, PEC Personnel, Clients or others, including meeting child-protection reporting obligations.
23. Client Responsibilities
Where PEC provides services to a Client, the Client is generally responsible for:
determining the purposes for collecting and using student and family information;
deciding what information PEC Personnel may access;
providing privacy notices and obtaining consent or other lawful authority, including from parents and guardians;
deciding whether sessions are recorded and providing related notices;
selecting, administering and securing Client technology, including privacy and security settings and account access;
removing PEC Personnel's access to Client systems when an assignment ends;
managing retention within Client systems;
responding to requests and complaints about Client-controlled information; and
notifying affected individuals of incidents within Client systems where the law places that duty on the Client.
PEC may rely on Client representations about these matters unless circumstances reasonably indicate otherwise. Nothing in this Policy transfers to PEC a responsibility that applicable law or a written agreement places on a Client, and nothing relieves PEC of obligations applicable law independently places on PEC.
24. Allocation of Responsibility and Limitation of Liability
24.1 Reasonable measures, not guarantees. PEC takes reasonable administrative, technical, contractual and organizational measures to protect personal information in accordance with applicable law. However, no information system, internet transmission, cloud service, third-party platform or storage system can be guaranteed to be completely secure, uninterrupted or error-free. Nothing in this Policy is a representation, warranty or guarantee that unauthorized access, cyberattacks, technical failures, service interruptions, data loss, malicious activity, human error or other privacy or security events will never occur.
24.2 Third parties. PEC relies on Clients, Recruitment Providers, cloud and technology providers and other Service Providers. PEC takes reasonable measures when selecting and managing the providers it is responsible for, but does not operate or control their infrastructure, security architecture, availability or independent conduct.
24.3 Client-controlled systems. Where a platform, system or account is selected, purchased, configured, administered or controlled by a Client, the Client is responsible for it except to the extent PEC has expressly accepted responsibility in writing or applicable law places responsibility on PEC.
24.4 Limitation of liability. To the maximum extent permitted by applicable law, PEC is not liable for:
the independent acts, omissions, misconduct, security failures or unlawful activities of Clients, Recruitment Providers, Service Providers, their subprocessors or other third parties, where applicable law does not impose responsibility for them on PEC;
the acts of PEC Personnel who act outside the scope of their authorization, where applicable law does not impose responsibility for them on PEC;
Privacy Incidents or losses caused by events beyond PEC's reasonable control, including cyberattacks on third-party systems, infrastructure failures and acts of government;
Privacy Incidents or losses caused by an individual's own devices, networks, accounts or credentials, or by information an individual chooses to disclose beyond what PEC requested; or
indirect, incidental, consequential, special or punitive damages arising from the handling of personal information by any third party.
24.5 What this Policy does not do. Nothing in this Policy:
excludes or waives a statutory privacy right that cannot lawfully be excluded or waived;
excludes liability or obligations that applicable law does not permit PEC to exclude;
transfers to any individual an obligation that applicable law places on PEC; or
requires PEC to assume an obligation that applicable law or a written agreement places on a Client or independent third party.
PEC's obligations regarding personal information are determined by applicable law and, where relevant, by contractual allocations of responsibility.
25. Complaints, Changes, Interpretation and Contact
25.1 Questions and complaints. Questions, requests, concerns or complaints about PEC's privacy practices may be sent to the Privacy Officer. PEC will review each concern, investigate as appropriate, and respond. Nothing in this Policy restricts your right to contact a privacy regulator, such as the Office of the Information and Privacy Commissioner for British Columbia or the Office of the Privacy Commissioner of Canada.
25.2 Changes to this Policy. PEC may update this Policy to reflect changes in law, operations, technology, services or practices. The current version will show its last updated date. Where a change materially affects how we use or disclose information already collected, PEC will provide additional notice and obtain consent where required by law.
25.3 Interpretation. This Policy describes PEC's privacy practices and commitments. Except where required by applicable law or agreed in writing, including in a signed acknowledgment, this Policy does not create contractual rights, guarantees or warranties beyond those imposed by applicable law. Nothing in this Policy waives any defence, limitation, privilege or protection legally available to PEC. If a provision conflicts with a mandatory requirement of applicable law, that requirement governs to the extent of the conflict, and the rest of this Policy remains in effect. Headings are for convenience only.
25.4 Contact
Privacy Officer, Purpose Education Collective Inc. 999 Canada Place, Suite 404, Vancouver, BC V6C 3E2
Contact: privacy@purpose-educate.com