Privacy Policy

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Effective date: October 2026

Open Ice Initiative ("OII", "we", "us" or "our") runs free hockey camps in Toronto for children from low-income and newcomer families. Families trust us with information about their children and their households, and we take that trust seriously. This policy explains, in plain language, what personal information we collect, why we collect it, how we protect it, and the choices you have.

We have built our practices around the ten fair information principles set out in Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and the guidance of the Office of the Privacy Commissioner of Canada. We follow these principles as our standard for everyone we serve, whether or not a particular law requires it.

1. Who we are

Open Ice Initiative is a not-for-profit corporation incorporated in Ontario, Canada. We are responsible for the personal information under our control, including information handled for us by our service providers.

Our Privacy Lead, Andrew Adair, Founder and President, is accountable for this policy and for how we handle personal information. You can reach the Privacy Lead at openiceinitiative@gmail.com.

2. What this policy covers

This policy applies to personal information we collect through our website, our online registration form, email, our camps and events, and our volunteer and donor activities. It does not apply to other organizations' websites, even if we link to them.

3. Information we collect

We only collect what we need for the purposes described in section 4. Depending on how you interact with us, this may include:

Parent or guardian information

• Name, email address, phone number and home address
• Preferred language for communication
• Relationship to the child
• Emergency contact names and phone numbers

Child information

• Name, date of birth and age group
• Hockey and skating experience, and equipment sizes so we can provide gear
• School or community agency, if you choose to tell us how you heard about us

Health and safety information

• Allergies, medical conditions, medications and dietary needs
• Accessibility or support needs that help us include your child safely
• Ontario health card number only if it is needed on a medical or emergency form

We treat this information as sensitive. We use it only to keep your child safe and to respond in an emergency.

Household income information

• Household size
• Your household income, as an amount or a range
• If you choose to share one, a document showing household income or eligibility, such as a Canada Child Benefit notice, Notice of Assessment, Ontario Works or ODSP statement, recent pay stubs, or a letter from a community agency. Sharing a document is optional, and an application without one is considered in the same way.

Please black out your Social Insurance Number (SIN) and any bank account numbers before uploading. We do not need them and do not want them. If a document arrives with a SIN visible, we will not record the number, and we will redact or delete the file.

We treat financial information as sensitive. We use it only to confirm that your family is eligible for our free programs.

Optional demographic information

• Questions about things such as the languages spoken at home, how long your family has been in Canada, gender, and racial or Indigenous identity

These questions are always optional and always include a "prefer not to say" choice. Answering or not answering has no effect on whether your child can take part. We use these answers only in combined, anonymous form (for example, the share of campers who speak a language other than English at home) to understand who we are reaching and to report to funders. We never share individual answers.

Photos and video

• Photos and video taken at camps and events, but only of children whose parent or guardian has given photo consent (see section 9)

Volunteers, coaches and donors

• Volunteer and coach contact details, availability and relevant certifications
• Donor names and contact details if you choose to share them with us. Donation payments are processed by third-party platforms such as GoFundMe, and we do not receive or store your full payment card details

Website and technical information

• Hosting logs: our website is hosted by Vercel. Like most web hosts, Vercel automatically processes technical information such as IP address, browser type and pages requested, to deliver the site and protect it from abuse.
• Analytics: if we use website analytics, we use basic, aggregate tools that count visits and popular pages. We do not use analytics to identify individual visitors, and we do not use advertising or tracking cookies.
• Blog: our blog is provided through an embedded service called Soro. When you view blog content, Soro may receive technical information such as your IP address and browser details under its own privacy terms.
• Email: we send registration confirmations and program updates through Resend, an email delivery service. Resend processes your email address and the message content in order to deliver our emails.

4. Why we collect it

We tell you why we need information at or before the time we ask for it. We use personal information to:

• Process registrations, confirm eligibility and select participants fairly
• Communicate with families about schedules, changes, reminders and follow-up
• Keep children safe, respond to medical needs and contact parents or guardians in an emergency
• Provide and fit equipment
• Recruit and coordinate volunteers and coaches
• Thank donors and supporters and respond to their questions
• Prepare anonymous, combined statistics to evaluate and improve our programs and to report to funders and partners
• Share stories and photos of our programs, only with consent
• Operate, secure and improve our website
• Meet legal, insurance and safety obligations

If we want to use your information for a new purpose, we will ask for your consent first, unless the law allows or requires otherwise.

5. Consent

We collect, use and share personal information with your knowledge and consent, except where the law permits or requires otherwise.

• Express consent: we ask for clear, express consent before collecting sensitive information, such as health, allergy and household income information, and before taking or sharing photos of your child.
• Children's information: a parent or legal guardian must register a child and give consent on the child's behalf. In line with the Office of the Privacy Commissioner of Canada's guidance, we do not rely on consent from children under 13. For older youth, we also explain things in age-appropriate language and respect their views, for example if a teen does not want to be photographed.
• Optional choices: photo consent, demographic questions and newsletters are separate, optional choices. Saying no to any of them does not affect your child's eligibility.

Withdrawing consent

You can withdraw or change your consent at any time by emailing openiceinitiative@gmail.com. We will explain any effect this may have. For example, we cannot run a child safely in a camp without emergency contact and medical information, and we cannot confirm eligibility without income information. If you withdraw photo consent, we will stop using your child's images in new materials and will remove them from our website and social media accounts that we control, although we may not be able to recall printed materials already distributed.

6. How we store and protect information

We protect personal information with safeguards that match its sensitivity. These include:

• Limited access: registration records and uploaded documents are kept in a password-protected staff portal. Only a small number of authorized staff and designated volunteers who need the information for their role can see it. Household income documents can be viewed only by the people who review eligibility.
• Technical safeguards: encrypted connections (HTTPS), private file storage that is not publicly linked, strong passwords and, where available, multi-factor authentication.
• Practical safeguards: we do not send income documents by email internally, we do not keep copies on personal devices, and camp-day health and emergency information is kept with the camp lead and returned or destroyed after each camp.
• People: staff and volunteers who handle personal information agree to keep it confidential and receive guidance on these practices.

No system is perfectly secure. If a privacy breach creates a real risk of significant harm to you or your child, we will notify you as soon as possible and tell you what we are doing about it, and we will report it to the appropriate authorities where required.

7. How long we keep information

We keep personal information only as long as we need it for the purposes above, then securely delete or destroy it.

• Household income documents: deleted as soon as eligibility is confirmed and in all cases no later than 90 days after the camp ends. For applications that are not accepted or are withdrawn, documents are deleted within 90 days of the decision. We keep only a short note of the eligibility decision (not the document).
• Health and allergy information: deleted no later than 90 days after the camp ends, unless an incident occurred, in which case related records are kept as long as needed for insurance or legal reasons.
• Registration and contact records: kept for up to 2 years after your child's last camp so we can invite you back and respond to questions, unless you ask us to delete them sooner.
• Signed waivers, consent forms and incident reports: kept for as long as required by our insurer or by law. Because legal limitation periods for minors can run until after a child turns 18, some of these records may be kept for several years.
• Demographic answers: kept only in anonymous, combined form after reporting is complete.
• Photos and video: kept for as long as they are used in our materials, or until consent is withdrawn.

8. When we share information

We never sell, rent or trade personal information. We share it only in these limited situations:

• Service providers that help us run our website and programs, such as our website host (Vercel), our email delivery provider (Resend), our blog provider (Soro), and file storage or form tools. They may use the information only to provide services to us and must protect it.
• Rink and facility partners, insurers and emergency responders when needed for safety, an emergency or an insurance claim, and only to the extent necessary.
• Funders and partners receive only anonymous, combined statistics, never information that identifies a child or family, unless you give us separate permission (for example, to share a family's story).
• Where required by law, for example in response to a valid court order, or where we have a legal duty to report a concern about a child's safety to a children's aid society.

9. Photos, video and media

We love sharing the joy of our camps, but your child's image belongs to your family. We will only photograph or film your child, and only use those images on our website, social media, newsletters, fundraising pages or media stories, if a parent or guardian has given photo consent on the registration form.

• Photo consent is optional and is separate from registration.
• We do not publish children's full names, schools or home neighbourhoods with their images.
• We ask parents, volunteers and guests not to post photos of other people's children taken at our camps without permission.
• Children without photo consent may be given a visual marker (such as a coloured sticker or pinnie) so our photographers can avoid them.
• You can withdraw photo consent at any time, as described in section 5.

10. Children's privacy

Our programs serve children, so we take extra care:

• Children cannot register themselves. Registration and consent must come from a parent or legal guardian.
• We collect only the child information needed to run a safe, fun camp.
• Our website is intended for parents, guardians, volunteers and supporters. We do not knowingly collect personal information online directly from children under 13. If we learn that we have, we will delete it.
• We never use children's information for marketing.

11. Storage outside Canada

Some of our service providers, including Vercel and Resend, are based in the United States, and personal information may be stored or processed outside Canada, including in the United States. While it is there, it is subject to the laws of that country and may be accessible to its courts, law enforcement and national security authorities. We choose providers that use recognized security practices, and we remain responsible for protecting your information when it is handled on our behalf. If you have questions about where your information is stored, please contact us.

12. Your rights: access and correction

You have the right to ask:

• whether we hold personal information about you or your child;
• to see that information, and how it has been used and shared;
• to correct information that is inaccurate or incomplete; and
• to have information deleted when it is no longer needed.

Send your request to openiceinitiative@gmail.com. We may need to confirm your identity, and that you are the child's parent or legal guardian, before releasing information. We will respond within 30 days, free of charge. If we cannot give you access to some information (for example, because it would reveal information about another person), we will explain why. You can ask us to communicate in another language and we will do our best to help.

13. Questions and complaints

If you have a question or concern about how we handle personal information, please contact our Privacy Lead first at openiceinitiative@gmail.com. We will look into every concern, tell you what we found, and fix any problem we identify, including updating our practices where needed.

If you are not satisfied with our response, you can contact the Office of the Privacy Commissioner of Canada:

• Website: www.priv.gc.ca
• Mail: 30 Victoria Street, Gatineau, Quebec K1A 1H3

14. Changes to this policy

We review this policy at least once a year and update it when our programs, tools or legal requirements change. We will post the updated version on this page with a new effective date. If we make a significant change, such as using information for a new purpose or sharing it with a new type of organization, we will notify registered families by email and ask for consent where required.

15. Contact us

Open Ice Initiative
Toronto, Ontario, Canada
Email: openiceinitiative@gmail.com