Privacy Policy EMME Consulting Inc.

Privacy Policy

EMME CONSULTING INC.

Effective Date: December 1, 2025

Last Updated: December 1, 2025

1. INTRODUCTION

EMME Consulting Inc. (“we,” “us,” “our,” or “the Company”) is committed to protecting the privacy and personal information of all participants, parents, guardians, and visitors who use our services and website. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Alberta privacy legislation.

Owner: Mark Korthuis

Location: Edmonton, Alberta, Canada

By using our services, registering for programs, or visiting our website, you consent to the collection and use of your personal information as described in this Privacy Policy.

2. DEFINITIONS

“Personal Information” means any information about an identifiable individual, including but not limited to name, address, email, phone number, date of birth, medical information, and payment details.

“Sensitive Personal Information” includes medical conditions, allergies, emergency contacts, and any information that could impact a participant’s health or safety.

“Minor” means any individual under the age of 18.

“Parent/Guardian” means the legal parent or guardian of a minor participant.

“Services” includes all soccer programs, camps, training sessions, events, and related activities.

3. WHAT INFORMATION WE COLLECT

Personal Information of Participants

We collect the following information during program registration and participation:

Contact Information:

  • Full name (first and last)
  • Date of birth
  • Mailing address
  • Email address (for youth participants where appropriate)

Parent/Guardian Information:

  • Full name
  • Phone number(s)
  • Email address
  • Relationship to participant

Emergency Contact Information:

  • Name of emergency contact person(s)
  • Phone number(s)
  • Relationship to participant

Medical and Health Information:

  • Known allergies and sensitivities
  • Medical conditions that may affect participation
  • Current medications
  • Dietary restrictions
  • Physical limitations or special needs
  • Health insurance information (where required)

Program-Related Information:

  • Previous soccer experience
  • Skill level assessment
  • Program preferences
  • Attendance records
  • Performance assessments (for development purposes)

Payment Information

  • Credit/debit card information (processed through secure third-party payment processors)
  • Billing address
  • Transaction history
  • Refund records

Website and Communication Information

  • IP address and browser information (when visiting our website)
  • Email communication history
  • Consent records for marketing communications
  • Feedback and survey responses

Photographs and Video

  • Images and video footage captured during programs (with consent)
  • Media release authorization records

4. HOW WE COLLECT INFORMATION

We collect personal information through:

Direct Collection:

  • Online registration forms
  • Paper registration forms
  • Email and phone communications
  • In-person interactions at programs and events
  • Medical and emergency contact forms

Automatic Collection:

  • Website cookies and analytics (see Section 12)
  • Payment processing systems
  • Email marketing platforms

Third-Party Sources:

  • References provided by other programs or organizations (with consent)
  • Partner organizations for joint programming

5. HOW WE USE YOUR INFORMATION

We use personal information for the following purposes:

Program Administration

  • Processing program registrations and payments
  • Communicating program schedules, changes, and updates
  • Managing attendance and participant records
  • Coordinating logistics and facility bookings

Health and Safety

  • Ensuring appropriate care for participants with medical conditions
  • Responding to medical emergencies
  • Providing necessary information to medical personnel when required
  • Assessing participant readiness for physical activity

Communication

  • Sending program confirmations and receipts
  • Providing updates about programs and schedule changes
  • Responding to inquiries and customer service requests
  • Sending newsletters and promotional materials (with consent)

Program Development

  • Assessing participant skill levels and progress
  • Improving program quality and curriculum
  • Conducting satisfaction surveys and gathering feedback
  • Planning future programs based on demand and interests

Legal and Compliance

  • Complying with legal obligations and regulations
  • Maintaining records for insurance and liability purposes
  • Responding to legal requests and court orders
  • Protecting the rights and safety of participants and staff

Marketing and Promotion

  • Promoting programs through photographs and testimonials (with consent)
  • Sharing success stories and program highlights
  • Creating promotional materials for future programs

We do not use personal information for purposes other than those listed above without obtaining additional consent.

6. HOW WE SHARE YOUR INFORMATION

Limited Disclosure

We do not sell, trade, or rent personal information to third parties. We may share information only in the following circumstances:

Service Providers:

  • Payment processors (for secure transaction processing)
  • Email marketing platforms (for communications)
  • Facility partners (for program logistics)
  • Insurance providers (for coverage requirements)
  • IT service providers (for data storage and security)

All service providers are contractually required to protect personal information and use it only for specified purposes.

Emergency Situations:

  • Emergency medical personnel (when participant safety requires)
  • Parents/guardians (regarding their child’s participation and wellbeing)
  • Emergency contacts (when parents/guardians cannot be reached)

Legal Requirements:

  • Law enforcement (when required by law)
  • Courts (in response to subpoenas or court orders)
  • Child protection services (if abuse or neglect is suspected)
  • Government agencies (for regulatory compliance)

Partner Organizations:

  • Other soccer organizations (for tournament participation, with consent)
  • Facility operators (for access and safety requirements)
  • Photography services (for program photos, with consent)

With Consent:

  • Testimonials and success stories
  • Promotional materials featuring participants
  • Information sharing with other sports programs (upon request)

7. CONSENT

Obtaining Consent

We obtain consent for the collection, use, and disclosure of personal information through:

Express Consent:

  • Registration forms with clear consent statements
  • Signed media release forms
  • Opt-in checkboxes for marketing communications
  • Separate consent forms for sensitive information

Implied Consent:

  • Voluntary provision of information during registration
  • Continued participation in programs after policy updates

Consent for Minors

Parental/guardian consent is required for:

  • Collection and use of personal information for participants under 18
  • Medical and health information disclosure
  • Photography and video recording
  • Participation in programs and activities
  • Emergency medical treatment

Withdrawing Consent

You may withdraw consent at any time by:

  • Contacting us in writing at [email address]
  • Opting out of marketing communications through email links
  • Submitting a formal withdrawal request

Note: Withdrawal of certain consents may affect our ability to provide services or continue program participation.

8. PROTECTION OF MINORS’ INFORMATION

Special Protections for Children

We take extra precautions when collecting and handling information about minors:

Parental Involvement:

  • All information collection requires parental/guardian consent
  • Parents/guardians have the right to review their child’s information
  • Parents/guardians may request corrections or updates at any time

Limited Collection:

  • We collect only information necessary for program participation and safety
  • We do not collect more information from children than required
  • We do not use children’s information for marketing without explicit parental consent

Secure Handling:

  • Children’s information is stored with enhanced security measures
  • Access to minors’ information is restricted to authorized personnel only
  • Information is retained only as long as necessary for program purposes

Photography and Media:

  • Separate consent is required for any use of children’s images
  • Children are not identified by full name in public materials without additional consent
  • Parents may withdraw media consent at any time

9. DATA SECURITY

Security Measures

We implement appropriate technical and organizational measures to protect personal information:

Physical Security:

  • Secure storage of paper records in locked facilities
  • Restricted access to offices and filing systems
  • Secure disposal of documents (shredding)

Technical Security:

  • Encrypted data transmission (SSL/TLS)
  • Secure password-protected databases
  • Regular security updates and patches
  • Firewall and anti-virus protection
  • Secure backup systems

Administrative Security:

  • Staff training on privacy and data protection
  • Confidentiality agreements for employees and contractors
  • Access controls limiting who can view information
  • Regular privacy audits and reviews
  • Incident response procedures

Payment Security

  • Payment information is processed through PCI-DSS compliant third-party processors
  • We do not store complete credit card numbers on our systems
  • All payment transactions use secure encrypted connections

Data Breach Response

In the event of a data breach, we will:

  • Immediately investigate and contain the breach
  • Notify affected individuals as required by law
  • Report the breach to appropriate authorities
  • Take steps to prevent future breaches
  • Offer support and guidance to affected individuals

10. DATA RETENTION

Retention Periods

We retain personal information only as long as necessary for the purposes outlined in this policy:

Active Participants:

  • Information is retained throughout program participation and for the current season

Former Participants:

  • Basic contact and registration information: 7 years (for legal and insurance purposes)
  • Medical information: 7 years (for liability purposes)
  • Payment records: 7 years (for tax and accounting purposes)
  • Attendance and assessment records: 3 years (for reference purposes)

Marketing Contacts:

  • Contact information retained until consent is withdrawn or individual opts out
  • Inactive contacts may be removed after 2 years without engagement

Secure Disposal

When personal information is no longer needed:

  • Electronic records are permanently deleted or anonymized
  • Paper records are securely shredded
  • Backup copies are included in disposal procedures
  • Third-party service providers are required to dispose of information securely

11. YOUR PRIVACY RIGHTS

Under Canadian privacy law, you have the following rights:

Right to Access

  • Request a copy of your personal information we hold
  • Receive information about how your data is being used
  • Response provided within 30 days of request

Right to Correction

  • Request correction of inaccurate or incomplete information
  • Provide updated information as circumstances change
  • Receive confirmation when corrections are made

Right to Withdraw Consent

  • Withdraw consent for specific uses of your information
  • Opt out of marketing communications
  • Request cessation of certain data processing activities

Right to Complain

  • File a complaint with the Privacy Commissioner of Canada
  • Contact us directly with privacy concerns
  • Escalate unresolved issues to appropriate authorities

Exercising Your Rights

To exercise these rights:

  • Contact us in writing at mark@confront.co
  • Provide sufficient information to identify yourself
  • Specify the nature of your request
  • We will respond within 30 days and may request verification of identity

12. COOKIES AND WEBSITE TRACKING

Use of Cookies

Our website may use cookies and similar technologies to:

  • Remember user preferences and settings
  • Analyze website traffic and usage patterns
  • Improve website functionality and user experience
  • Track marketing campaign effectiveness

Types of Cookies

Essential Cookies:

  • Required for website functionality
  • Cannot be disabled without affecting site performance

Analytics Cookies:

  • Track website usage and visitor statistics
  • Help us understand how visitors interact with our site
  • Used to improve website design and content

Marketing Cookies:

  • Track visitors across websites
  • Used to display relevant advertisements
  • May be set by third-party advertising partners

Managing Cookies

You can control cookies through:

  • Browser settings (disable or delete cookies)
  • Third-party opt-out tools
  • Website cookie preference centers (where available)

Note: Disabling cookies may affect website functionality.

Third-Party Analytics

We may use services such as Google Analytics to analyze website traffic. These services may collect information about your use of our website, including IP address, browser type, and pages visited. Please refer to their privacy policies for more information.

13. EMAIL COMMUNICATIONS

Newsletter and Promotional Emails

  • We send newsletters and promotional emails only to those who have consented
  • Each email includes an unsubscribe link
  • Opt-out requests are processed within 10 business days
  • Transactional emails (receipts, confirmations) may still be sent after opting out

Communication Frequency

  • Program updates: As needed
  • Newsletters: Monthly (approximate)
  • Promotional offers: Periodic (not more than weekly)

Email Security

  • Emails are sent through secure platforms
  • We do not send sensitive information (passwords, full credit card numbers) via email
  • We verify identity before responding to email inquiries about personal information

14. THIRD-PARTY LINKS

Our website may contain links to third-party websites, including:

  • Social media platforms
  • Payment processors
  • Partner organizations
  • Facility booking systems

We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any external sites you visit.

15. UPDATES TO THIS PRIVACY POLICY

Policy Changes

  • This Privacy Policy may be updated periodically to reflect changes in our practices or legal requirements
  • The “Last Updated” date at the top indicates the most recent revision
  • Significant changes will be communicated through email or website notices
  • Continued use of our services after changes indicates acceptance of updated policy

Notification of Changes

We will notify you of material changes through:

  • Email to registered participants
  • Prominent notice on our website
  • Notification at time of next registration

16. CONTACT INFORMATION

Privacy Officer

For questions, concerns, or requests regarding this Privacy Policy or our privacy practices:

EMME Consulting Inc.

Privacy Officer: Mark Korthuis

  • Email: mark@confront.co
  • Phone: 1 (780) 920-5277

Privacy Commissioner of Canada

If you are not satisfied with our response to your privacy concerns:

Office of the Privacy Commissioner of Canada

  • Website: www.priv.gc.ca
  • Toll-free: 1-800-282-1376
  • Email: info@priv.gc.ca

17. CONSENT ACKNOWLEDGMENT

By registering for our programs or using our services, you acknowledge that:

  • You have read and understood this Privacy Policy
  • You consent to the collection, use, and disclosure of personal information as described
  • You understand your privacy rights and how to exercise them
  • For participants under 18, you are the parent/guardian providing consent on their behalf
  • You agree to notify us of any changes to personal information

Effective Date: December 1, 2025

Last Updated: December 1, 2025

Version: 1.0

This Privacy Policy is designed to comply with PIPEDA and Alberta privacy legislation. For specific legal advice regarding privacy compliance, consult with a qualified privacy lawyer or privacy professional.

EMME Consulting Inc. Edmonton, Alberta, Canada

Committed to protecting your privacy while delivering quality soccer programming.