PRIVACY POLICY

We are Willowbrae Academy (“We” “our” “us” “Willowbrae” or “Academy”), a network of early childhood education academies that focus on providing high-quality care and learning experiences for young children.

This Policy describes how Willowbrae Academy collects, uses, and discloses personal information when you visit our website at www.willowbraeacademy.com or when you download and use our Mobile Apps BRAEVIEW Parent App and BRAEVIEW Staff App or otherwise use or services (together, our “Services”). It also explains your rights regarding your personal information and how to contact us if you have any questions about our privacy practices.

For more information on our service offerings, visit www.willowbraeacademy.com.

Our website and Mobile App are not intended for use by anyone under the age of majority (18 or 19 years, depending on your jurisdiction). Any personal information about children that we collect, use, or disclose through provision of the Services is with the express consent of a child’s parent and/or guardian, and in compliance with applicable laws and this Privacy Policy. See the section below called “Student Information” for more detailed information.

Collection Of Personal Information

Personal information means any information about an individual from which that person can be identified. It does not include information that is de-identified or anonymized, and there is no possibility of re-identification.

Information Provided to Us

We collect personal information about you when you fill in forms on our site www.willowbraeacademy.com and any “Willowbrae Academy” domains and sub-domains, services, or apps operated by us from time to time (“our Sites”), or if you or someone that you have authorized correspond with us (for example, by phone, e-mail, chat or forum discussions), or download and use our Mobile App, create an account and profile within the App, subscribe to any of our programs, search for a program, or report a problem with our services or our Sites. The information you provide us may include your name, address, e-mail address, phone number, payment information (including images of personal cheques), your child’s information (see “Student Information”, below), and any other information you provide. With your express consent, we also use facial recognition and fingerprint scanning to allow you to physically access our premises.

Student Information

When you download and use our Mobile App and create a parent/guardian account and profile, we collect and use the following personal information relating to your child to provide the Services to you (“Student Information”). Student Information is collected directly from a parent/guardian with express consent, and is only visible to and accessible through the App by the child’s parent/guardian and our education providers and administrators, not to any other parent using the App (other than any live-feed video images of a classroom via the Liveview System, which is available to parents/guardians of the class who use the App):

• Name, age, date of birth and allergy/health information, including information about immunization;

• Video images (including live feed video) through our Liveview System;

• Tagged photographs;

• Information about daily activities at the academy.

Student Information is not shared with or disclosed to any third party except as provided in this Policy and is securely destroyed once it is not longer required for the purposes for which it was collected.

Information Collected Automatically

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. Google Analytics collects information about how you use Willowbrae websites or Mobile Applications. We use the information provided by Google Analytics to improve our services.

By using our services, you consent to the processing of data about you by Google as described here and in Google's privacy policy. You can control the information provided to Google and opt out of certain ads provided by Google by using one of the methods set forth in the how Google uses information from sites or apps that use our services, or the Google Analytics opt out browser add-on.

Willowbrae Academy uses Google analytics on its Sites to collect user information by the use of site cookies. The following table describes each cookie set by gtag.js.

Each time you visit our Sites we automatically collect the following information about your visit, including:

• the full Uniform Resource Locators (URL)

• clickstream to, through and from our Sites (including date and time)

• page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet

• broowser type and version

• time zone information

• approximate geolocation

• operating system and platform

Collection Of Personal Information

We require personal information to properly serve you and your family at our Academy. We use only lawful and fair means to collect your information and only collect what is reasonably necessary for the legitimate purposes identified and for which consent has been obtained. Whenever possible, we will collect your personal information directly from you or someone that you have authorized.

Sometimes, we may obtain information about you from other sources, including government agencies or other third parties who have the right to disclose your information to us.

How Will We Use Your Information?

We will identify the purpose of collection to the individual from whom the Personal Information is collected. If we plan to use personal information, we have collected for a purpose not previously identified, we will identify and document this purpose before such use and obtain your consent.

We may use your personal information for the following purposes:

• to process applications submitted, particularly with respect to childcare and employment;

• to provide childcare services to your children, including developing individualizes plans for each child;

• to provide compensation and benefits to employees;

• to manage and develop our business and operations;

• to communicate with you regarding current and future products and services;

• to follow up with any of your comments or suggestions;

• to assist with employee training;

• for security purposes;

• to investigate any requests for incident review;

• for billing and record-keeping;

• for account collection;

• to meet legal and regulatory requirements.

Disclosure Of Your Personal Information

We will not sell, share, trade or otherwise distribute your personal information to third parties, except in accordance with this Privacy Policy.

We may share personal information collected from you with our affiliates, or in the context of a business transaction, we may transfer such Information to a successor entity or to an entity which purchases substantially all of the assets of Willowbrae Academy.

We sometimes contract with outside organizations to perform specialized services such as hosting the Services. Our suppliers may at times receive, process or handle some of your personal information. Only the personal information necessary to perform the services under the contract is given to the supplier.

Under their contracts with us, our suppliers may use such personal information only to carry out the contracted service and must not store or use the information for any other purpose. Our contracts with suppliers require that they provide a level of protection for your personal information that is comparable to our own.

We may also disclose your personal information:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.

• to enforce or apply other agreements to which we are a party, including for billing and collection purposes.

• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Willowbrae, our customers, children in our care, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction

Consent And Withdrawing Your Consent

By submitting personal information to us, or our service providers and agents, you consent to the collection use, disclosure, and transfer of your personal information in accordance with this Privacy Policy and as permitted or required by law. You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your personal information time by contacting us at admin@willowbraechildcare.com. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may not be able to provide you, or continue to provide you, with certain products, services, or information that may be of value to you

Storage And Transfers Of Personal Information

We use appropriate security measures to protect against loss, theft, unauthorized access, disclosure, use or modification of personal information. Our security measures vary depending on the sensitivity, amount, format, nature and storage of the personal information and will involve, as applicable, physical, organizational and electronic security measures, including premises security, restricted file access, technological safeguards including security software and firewalls to prevent unauthorized computer access, and password and security policies.

We ensure our employees are aware of the importance of maintaining the confidentiality of personal information, and we will exercise care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.

Although we have enacted various security measures, we cannot guarantee the absolute security of our website, our Liveview System or the security of information that you submit (or that we send to you) over the internet, since no internet transmission is ever 100% secure or error-free. Your use of the internet, our software, and electronic mail is at your own risk.

Note that personal information may be stored, accessed, used and otherwise processed inside and outside of Quebec and/or Canada. When personal information is located outside Quebec and/or Canada, it may be subject to laws that have different standards of protection and may allow for foreign law enforcement and governmental access.

Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

Retention Of Personal Information

The personal information that you provide will be retained by Willowbrae in accordance with applicable laws and our internal retention policies. However, we will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for the purposes for which it was collected.

Access To Your Personal Information

We will take reasonable steps to ensure the personal information we hold is accurate, complete and up to date. Upon your written request, and subject to certain exceptions provided by law, we will inform you of the existence, use, and disclosure of your personal information and give you access to that information. We may charge a minimal fee for providing such access to you. If you believe that the personal information that we hold about you is not accurate or complete, you may write to us at admin@willowbraechildcare.com. If you are able to establish that the information is not accurate or complete, we will take reasonable steps to delete and/or correct the information so that it is accurate, complete, and up-to-date. In order to facilitate a request to correct or update information, we may ask you to provide additional information to confirm your identity. Any such information will only be used for the purpose of confirming your identity and will not be retained by us.

Changes to this policy

As part of our regular review of all our policies and procedures, we may change our privacy policy from time to time. If this Privacy Policy materially changes, we will take reasonable measures to notify you of these changes, including posting a copy of the revised Privacy Policy on our parent board. Your continued consent to our collection, use and disclosure practices following notification of any material change, your continued enrollment or employment in our Academy, and/or your continued access to our website and software following the posting of any changes to this Privacy Policy shall constitute your acceptance of those changes. You may also contact us if you would like us to send you a copy of the most current version of this Privacy Policy. This Privacy Policy was last revised on October 08, 2024.

Canada’s Anti-Spam Law (“CASL”)

We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message.

Third Party Links

Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal information that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal information to these websites or use these services.

Questions, Concerns or Requests for Access

We will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices. A client or employee shall be informed of the outcome of the investigation regarding his or her complaint.

Our goal is to protect your privacy and personal information. If you have any questions, comments or concerns about this Privacy Policy or our procedures affecting your

Chief Privacy Officer

Willowbrae Academy®

94 Garland Avenue, Suite 201

Dartmouth, NS B3B 0A7 Telephone: 902.481-5435

Email us at: admin@willowbraechildcare.com.