As is true of most other websites, the Site collects certain information automatically and stores it in log files. The information may include IP addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of our Site, including a history of the pages you view. When you visit our Site, we may send one or more cookies to your device. They enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse our Site and enhance the level of services and functions provided. Please review our Cookie Policy for more information.

Privacy Policy

This Privacy Policy applies to any ICI Inclusive Communities Institute / ICI Institut pour communauté inclusive (“ICI”) user or visitor of Inclusion New Brunswick Inc. / Inclusion Nouveau-Brunswick Inc.’s (“InclusionNB,” “we,” “us” or “our”) platform (“Services” or “Platform”) in connection with our website at https://ici.myabsorb.com (the “Platform”), and https://ici-nb.ca (the “Site”). We take your privacy seriously. This Privacy Policy describes our policies and practices regarding the collection, use and disclosure of personal information, and describes individual’s privacy rights. “Personal information” means information about an identifiable individual.

PLEASE READ THIS POLICY CAREFULLY. If you do not agree with the provisions of this Privacy Policy, please do not use our Site or our Services. By accessing or using this Site or our Services, you agree to the terms of this Privacy Policy. InclusionNB collects, uses and discloses personal information as described in this Policy.

Personal Information we collect

Personal Information. We collect personal information required to create a user account on our Site and to use the Services, which may include name, email address, phone number, username and password, or any information you provide through use of our Services. An individual, on their own behalf or on behalf of their organization, may register for an account and can access the Platform on their own time.

Information Collected Automatically

How we use personal information

InclusionNB will not use personal information for any purpose other than the purpose for which it was originally obtained without prior consent of the individual. We use your personal information to communicate with you, to provide our Services, and to provide support regarding our Services. We may use personal information to:

Contact you via e-mail, or by telephone regarding account status, inquiries, and information about our Services;
Enable you to register and log into our Portal and website;
Resolve service disputes; troubleshoot problems;
Collect (but not store) electronic payment data for transfer to a third-party payment processor (Stripe);
Respond to requests and inquiries about our Services;
Track statistics that help us improve our services; and/or
Provide system or administrative messages.

How we share Personal Information with others

We do not rent or sell personal information, and we do not share personal information with other people or nonaffiliated companies for their direct marketing purposes. We use third party service providers to perform functions or services on our behalf. When we transfer personal information to a service provider, we require all our service providers to maintain the privacy, confidentiality and security of the personal information and data. We take steps to ensure that these parties take protecting your privacy as seriously as we do. Within InclusionNB, personal information will be accessed only by those who have a need to provide the InclusionNB Services.

Types of Service Providers: We engage third parties to perform services on our behalf such as software maintenance services, hosting services, email service providers, database management, web analytics, and other services. Also, information may be shared with service providers when the Services are implemented or when software or other changes are required for support and maintenance purposes. We use vendors to help us on our behalf to provide the InclusionNB Services to you.

Law Enforcement and Internal Operations: Personal information may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against InclusionNB or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (iv) to protect the rights, property or safety of InclusionNB, its users or members of the general public. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third-party request to compel disclosure of your information.

Rights regarding Personal Information

Right to Access and Correct Your Personal Information: You may access your account at any time to correct, update, or delete inaccuracies relating to your personal information by logging into your account through our Site. You may delete your personal information by deleting your account. If additional assistance is required to change or delete inaccuracies within your personal information or you would like to know what information about you was collected, please contact us at privacy@inclusionnb.ca. We may charge a minimal fee for providing access to requested information. 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.

Right to Remove or Withdraw Consent: You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your personal information time by contacting us at privacy@inclusionnb.ca. 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.

If you receive communications from us and no longer wish to receive them, please follow the opt out or removal instructions in the email.
We may be required by law, to retain it to exercise or defend legal claims, or contractual obligations with our customers to retain some information in connection with our obligation to provide the Services.
We may de-identify and anonymize some data for purposes of retaining it.

Data Portability: If you would like us to transmit your personal information to another company providing similar services and we are required to so by law, we will work with them to do so upon written request and verification with both the requestor and the company receiving the personal information.

Communication: We will provide you reasonable mechanisms to exercise your choice regarding receipt of information from InclusionNB. When you receive an email from us, you may opt-out from receiving future emails from InclusionNB by clicking on the unsubscribe link contained in the e-mail, by writing to us at the address provided in the email, by contacting us at privacy@inclusionnb.ca. If you are a Canadian resident, 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.

Data Storage and Retention

Personal information is stored by InclusionNB on its servers, and on any servers of the cloud-based database management services InclusionNB engages. Except as otherwise stated herein, we will retain and use personal information for as long as an account is active, as needed to provide the Services, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact InclusionNB’s data protection officer at privacy@inclusionnb.ca.

Security

The security of your personal information is important to us. To help protect your privacy and personal information, we maintain physical, technical and administrative safeguards. We take reasonable and appropriate measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction by taking into due account the risks involved in the processing and the nature of the personal data.

All data used by the platform is encrypted both in transfer and at rest. All connections will be performed strictly under HTTPS protocol on all channels (transport layer security). The small padlock icon located on the left of our website address in your browser signifies that information sent or received through this Site is private. We restrict access to your personal information to those employees and authorized consultants and contractors who need to know that information to provide benefits or Services to you. Any employee that InclusionNB determines is in violation of this Privacy Policy will be subject to disciplinary action. InclusionNB may conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we store, process or transmit.

Children under the age of 16

InclusionNB does not permit children under the age of 16 to create an account and does not knowingly collect personally identifying information from children under the age of 16 without the consent of a parent or legal guardian. Please contact us at privacy@inclusionnb.ca if you believe we have inadvertently collected information from a child under 16 without parental consent so that we may delete the information as soon as possible. Please see our Privacy Policy for Children Under the Age of 16 to learn more about how InclusionNB collects, uses and shares information associated with a child’s profile.

Protection of Children's Personal Information and Compliance with Laws

Collection, use, and disclosure of personal information of children is governed by this Privacy Policy, our Terms of Use by the provisions of the Children's Online Privacy Protection Act ("COPPA") and other applicable laws that may relate to the collection and use of personal information of children, including PIPEDA and substantially similar provincial data protection laws (“Canadian Privacy Laws”).

If you have any questions about this Privacy Policy or about reviewing, modifying, or deleting the personal information, please contact us at privacy@inclusionnb.ca.

Links to other Websites

This Site may contain links to websites of other organizations. Unless otherwise specified, linkage to these other websites does not imply any relationship, sponsorship, or affiliation between InclusionNB and these linked websites, nor does it imply any adoption or approval of the content of such websites. InclusionNB does not have control over the policies or practices of these websites and is not responsible for their privacy practices or their content. We encourage you to review the privacy policies of any such other websites to understand their information practices.

Changes and updates to the Private Policy

As our company changes from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy, for any reason, without notice to you, other than the posting of the amended Privacy Policy. We may send you an email reminder of our notices and material changes, but you should check our Site frequently to see the current Privacy Policy is in effect and any changes that may have been made to it.

Questions, concerns, or complaints

InclusionNB commits to resolve complaints about your privacy and our collection or use of your personal information.

Please contact about any inquiries or complaints by email at icisupport@ici-nb.ca or by mail at:

Inclusion New Brunswick Inc. / Inclusion Nouveau-Brunswick Inc.

984 Prospect St Unit A, Fredericton, NB E3B 2T8

Attn: Data Privacy Officer

Last Updated: March 29, 2024.