Privacy Policy

Cultivating Generosity Privacy Policy

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Effective Date: November 11, 2025
Last Updated: November 11, 2025

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Purpose

Cultivating Generosity is committed to protecting the privacy and confidentiality of personal information collected from our clients, partners, and website visitors. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in accordance with:
• The Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada);
• Applicable Ontario privacy laws, including the Freedom of Information and Protection of Privacy Act (FIPPA) and, if applicable, the Personal Health Information Protection Act (PHIPA);
• Industry best practices for consultants and nonprofit professionals in Canada.

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Scope

This policy applies to all personal information collected, used, or disclosed by Cultivating Generosity in the course of providing consulting services, coaching, training, or digital communications.

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Definition of Personal Information

Under PIPEDA, 'personal information' refers to any information about an identifiable individual, including name, contact details, employment information, opinions, and financial data.

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Accountability

Cultivating Generosity is responsible for all personal information under its control. A designated Privacy Officer ensures compliance with this policy and applicable privacy legislation.

Privacy Officer:
Debbie Kesheshian
Email: <<privacy@cultivatinggenerosity.ca>>
Phone: 249-535-1501

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Collection of Personal Information

We collect only the information necessary for identified purposes such as providing services, communicating with clients, managing billing, and improving services. Information is collected directly from individuals or organizations with consent, except where permitted by law.

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Consent

We obtain informed consent before collecting, using, or disclosing personal information, except where authorized or required by law. Consent may be expressed or implied, and may be withdrawn at any time by contacting the Privacy Officer.

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Use and Disclosure of Personal Information

We use personal information solely for the purposes for which it was collected, unless consent is provided for another use or disclosure is required by law. We may share information with trusted subcontractors or service providers bound by confidentiality agreements. We do not sell or rent personal information.

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Data Retention

Personal information is retained only as long as necessary to fulfill its purposes and comply with legal requirements. When no longer needed, data is securely destroyed, erased, or anonymized. Typical retention: client files—7 years; financial records—as required by the CRA.

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Safeguards

We employ physical, technical, and administrative measures to protect personal information, including password protection, encryption, limited access, and secure disposal of records.

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Access and Accuracy

Individuals have the right to request access to their personal information, request corrections, and inquire about its use or disclosure. Requests must be made in writing to the Privacy Officer, and we respond within 30 days per PIPEDA/FIPPA requirements.

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Cookies and Website Analytics

Our website may use cookies and analytics tools to enhance user experience. Cookies collect non-identifiable data such as browser type and pages visited. Users can disable cookies in their browser settings.

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Cross-Border Data Transfers

Where data is stored or processed outside of Canada, it may be subject to foreign laws. We select vendors who comply with PIPEDA-equivalent safeguards.

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Email Communications

We comply with Canada’s Anti-Spam Legislation (CASL). Marketing emails are sent only with consent, and users may unsubscribe at any time via email or the unsubscribe link.

 

Updates to This Policy

This policy may be reviewed and updated periodically to reflect legislative or operational changes. The most current version will be available on our website.

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Questions or Concerns

Questions, concerns, or complaints regarding personal information handling may be directed to:

Cultivating Generosity
Attn: Privacy Officer
Email: <<privacy@cultivatinggenerosity.ca>>
Mailing Address: <<Mailing Address>>
Phone: 249-535-1501

If unsatisfied with our response, you may contact the Office of the Privacy Commissioner of Canada (www.priv.gc.ca).

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Compliance Summary

This policy complies with:
• PIPEDA (federal)
• FIPPA/PHIPA (Ontario)
• CASL (anti-spam law)
• CRA record retention requirements
• Best practices for Canadian consultants and nonprofit professionals