Privacy Policy

Key points

• We collect information needed to create and secure your account, personalize the App, and understand how it is working.
• Precise location, camera access, and photos are used only when you activate a feature that needs them, such as verifying your presence or adding a memory photo to a Pass. The App is not designed to continuously track your precise location or collect it in the background.
• The artificial intelligence assistant is optional. Your messages and the context needed to answer may be sent to an AI provider. Avoid entering sensitive or confidential information.
• We do not sell or rent personal information. Regional partners and sponsors normally receive only aggregated or de-identified reports.
• You can manage notifications, location, camera, and photo access in your device settings and can request access, correction, or deletion of your information.

1. Accountability and roles

WPT is responsible for the technical operation of the App and the practices described in this Policy. The NWRSC and community partners may create or approve public content, announcements, resources, events, attractions, deals, or Passes. They do not automatically receive access to your personal account because they administer content.

We designate a Privacy Officer to receive questions and requests. Contact details appear in the “Contact us” section.

2. Information we collect

Account, profile, and registration information. When you create an account or use a feature that requires sign-in, we may collect your name, email address, authentication identifiers, display name, preferred language, selected region, selected user type or experience mode, and information you voluntarily provide during registration or onboarding.

When you choose a student or school-related experience, we may process the selected mode and associated school or community context to display appropriate content. We do not ask a school to transfer your student record to us as part of the App’s normal operation.

Preferences, responses, and saved content. We may collect your interests and preferences, questionnaire, poll, or form responses, checklist activity, favourites, saved, dismissed, or viewed content, and feedback you choose to provide. Optional fields may be left blank.

Usage, analytics, and technical information. We may collect screens and features viewed, impressions and clicks, searches, time spent using a feature, interactions with advertisements and notifications, and the date and frequency of activity. We may also process IP address, device type, operating system, App version, language, technical identifiers, push notification token, error logs, and diagnostic information.

Passes, check-ins, location, and photos. When you attempt a Pass check-in, the App may request your precise location and send the coordinates, time, location or stop involved, calculated distance, and check-in result to confirm that you are at the required place. We may retain your Pass participation, check-ins, progress, and completion status.

When you take or choose a memory photo, the App accesses the camera or photo library only with your permission. The selected photo is uploaded to our systems and associated with the Pass stop. Other photos on your device are not uploaded.

Artificial intelligence assistant. When you voluntarily use the AI assistant, we may process your message, generated response, conversation history or summary, language and regional preferences, and App context needed to answer. The assistant can produce inaccurate, incomplete, or outdated information and does not replace professional advice or an official source.

The assistant does not make final decisions about eligibility for employment, a program, a service, or a benefit. We do not sell AI conversations, and we do not use your personal information to train or fine-tune public AI models.

Support, feedback, and communications. When you contact us, we may collect your contact details, message content, attachments, support history, and information needed to respond.

3. How information is collected

We collect information directly from you, automatically when you use the App, through permissions you grant on your device, and through providers that help us operate the App. Public content may come from the NWRSC, community partners, or approved public sources and is not necessarily personal information about you.

4. How we use information

We use personal information only for purposes that a reasonable person would consider appropriate, including to:

• provide, operate, secure, maintain, and improve the App;
• create and manage accounts, authenticate users, and recover access;
• personalize content based on language, region, user mode, and preferences;
• display relevant resources, events, attractions, jobs, deals, announcements, Passes, and community information;
• verify check-ins, record Pass progress, and store selected memory photos;
• provide the AI assistant and improve the quality, reliability, and safety of its responses;
• send notifications, service updates, and communications you have authorized;
• produce aggregated statistics, measure use, fix problems, prevent abuse, and meet legal obligations.

5. Consent and choices

We seek meaningful consent in light of the sensitivity of the information and reasonable expectations. Essential features require some processing to provide the service you request. Optional features are activated by your choice or a separate device permission.

You can:

• deny or withdraw notification, location, camera, or photo-library permission in your device settings;
• choose not to use the AI assistant or Pass features that require location or a photo;
• change your language, region, user mode, and certain preferences in the App;
• unsubscribe from optional communications where an option is provided;
• stop using the App and request deletion of your account.

Withdrawing permission does not undo processing already completed and may prevent a feature from working. For example, a location-based check-in cannot be completed without location access.

6. How we share information

Service providers. We may share information needed by providers that support hosting, databases, file storage, authentication, notifications, analytics, error monitoring, App distribution, maps, and AI processing. They may process information to provide services to us and are subject to applicable contractual, security, and privacy obligations.

Regional, community, and sponsoring partners. The NWRSC, community partners, and sponsors may receive aggregated or de-identified reports about use, trends, content performance, and campaigns. In the ordinary course of content administration, they do not have access through the content management system to individual account records, precise check-in coordinates, memory photos, AI conversations, or support messages.

We may share specific information with a partner when you ask us to resolve an issue with that partner, when sharing is necessary to provide a feature you requested, or when required or permitted by law.

Legal requirements and business transactions. We may disclose information when required by law, court order, or legal process, to protect rights, safety, or the integrity of the App, or in connection with a merger, financing, restructuring, or sale of assets, subject to appropriate safeguards.

We do not sell or rent your personal information.

7. Third-party providers and processing outside Canada

Depending on enabled features, providers may include cloud hosting and storage services, OneSignal for notifications, Expo and app stores for distribution, Apple or Google map services, analytics and monitoring tools, and OpenAI or another AI provider for artificial intelligence features.

Some providers may process or store information outside New Brunswick or Canada. Information may then be subject to the laws of the jurisdiction where it is processed. WPT remains accountable for information transferred to its providers and uses contractual and organizational safeguards appropriate to the risk.

8. Retention, deletion, and backups

We retain information only as long as needed for the purposes described, App operations, security, support, reporting, dispute resolution, and legal obligations. Retention periods vary by information type and feature.

When an account is deleted:

• the active account record and direct identifiers that are no longer needed are deleted or disabled;
• some questionnaire responses may remain associated with a deleted technical user identifier that is no longer connected to the account record;
• analytics events, aggregated statistics, some AI conversations, security logs, Pass check-in records, and support records may remain in de-identified, pseudonymized, or operational form when needed for the stated purposes;
• memory photos and other account-linked information are deleted, de-identified, or retained for a limited period according to our schedules, technical constraints, and applicable obligations;
• deleted information may remain temporarily in backups until the relevant backup expires or is replaced.

We do not attempt to re-identify de-identified information except where permitted and necessary for security, verification, or compliance.

9. Security

We use reasonable administrative, technical, and organizational safeguards, including encryption in transit, role-based access controls, restricted production access, secret management, logging, monitoring, and backups. No system is perfectly secure, so we cannot guarantee absolute security.

When an incident creates a real risk of significant harm, we take the notification, record-keeping, and mitigation steps required by law.

10. Your rights and requests

Subject to legal exceptions, you may:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• withdraw consent for an optional feature;
• request deletion of your account and associated information;
• ask a question or challenge our compliance with this Policy.

We may need to verify your identity before responding. If we refuse all or part of a request, we will explain why where permitted by law. You may also contact the Office of the Privacy Commissioner of Canada if a concern remains unresolved.

11. Children and young users

The App is not intended to allow children under 13 to independently create an account. When a person cannot provide meaningful consent, consent from a parent, guardian, or authorized organization may be required. Student and youth-oriented features should be used with appropriate authorization and supervision.

Contact us if you believe a child provided personal information without the required authorization so we can review the situation.

12. Advertising, sponsored content, and external links

The App may display sponsored content, deals, or advertisements. Selection may use general App context, language, selected region, or broad non-sensitive interests. We may measure impressions, clicks, and engagement and provide sponsors with aggregated reports. Sponsors do not receive individual account records through those reports.

The App may link to external websites, maps, forms, or services. Their practices are governed by their own policies, which you should review before providing information.

13. Changes to this Policy

We may update this Policy to reflect changes to the App, providers, practices, or legal requirements. We will post the updated version and date. We will provide additional notice and obtain new consent when required by law for a material change.

14. Contact us

For an access, correction, or deletion request, or a privacy question, contact:

Privacy Officer, Welcome Platform Technologies Inc.

Use the website contact form or the in-App support and account-deletion tools. Include “Privacy request — MonNoroît” in your message.

For a question only about public regional content, you may also consult the Northwest Regional Service Commission.