Privacy Policy
CREATIVE ARTS CONNECT
Privacy Policy
Effective Date: January 1, 2025
Last Updated: 2025
Version 2.0 — Includes Consent Framework Update
Creative Arts Connect ("CAC", "we", "us", or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our therapist matching platform located at creativeartsconnect.com and related subdomains (collectively, the "Platform").
By accessing or using our Platform, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with the practices described in this policy, please do not use our Platform.
This Privacy Policy is governed by and complies with the Personal Health Information Protection Act (PHIPA), the Personal Information Protection and Electronic Documents Act (PIPEDA), and applicable Canadian privacy legislation.
1. WHO WE ARE
Creative Arts Connect is a Canadian therapist matching platform that connects individuals with vetted, certified creative arts therapists specializing in art, music, dance, drama, play, and expressive arts therapy.
Data Controller:
Creative Arts Connect
2. INFORMATION WE COLLECT
We collect several types of information from and about users of our Platform.
2.1 Information You Provide Directly
Full name and preferred name
Email address
Quiz and assessment responses (including emotional state, therapy preferences, and goals)
Freeform text responses describing your therapeutic goals or needs
Communication preferences
Information about who you are seeking therapy for (yourself, a child, or someone in your care)
2.2 Information Collected Automatically
IP address and approximate geographic location
Browser type and version
Device type and operating system
Pages visited and time spent on the Platform
Referral source (e.g., which advertisement or link brought you to the Platform)
Cookie and tracking data (see Section 7)
2.3 Information from Third Parties
If you use social sign-in (Google, Facebook), we receive your name and email address from those providers in accordance with their privacy policies
Analytics data from advertising platforms including Meta (Facebook/Instagram) and Google Ads
3. HOW WE USE YOUR INFORMATION
We use the information we collect for the following purposes:
3.1 Core Platform Services
To process your matching assessment and curate personalised therapist recommendations
To connect you with vetted, certified Canadian creative arts therapists
To communicate your match results and therapist profiles via email
To manage your account and facilitate platform communications
3.2 Platform Improvement
To analyse how users interact with the Platform to improve matching accuracy and user experience
To identify and resolve technical issues
To develop new features and services
3.3 Communications
To send you your therapist match results
To send follow-up communications related to your therapeutic journey (with your consent)
To send platform updates, policy changes, and service announcements
To respond to your enquiries and support requests
3.4 Legal and Safety
To comply with applicable laws and regulations
To enforce our Terms of Service
To protect the safety and rights of our users and platform
3.5 Advertising (with appropriate consent)
To measure the effectiveness of our advertising campaigns on Meta and Google
To create anonymised audience segments for advertising purposes
We do not use your health-related quiz responses for advertising targeting
4. LEGAL BASIS FOR PROCESSING
⚠ Updated in Version 2.0 — Consent Framework Added
We process your personal information on the following legal bases under PIPEDA and applicable Canadian law:
Consent: Where you have provided explicit, informed consent at the point of form submission, including: consent to collect health-adjacent assessment responses; consent to use those responses for therapist matching; consent to share a matching profile summary with matched therapists; and opt-in to marketing communications and non-essential cookies. Consent is obtained via a clearly labelled affirmation at the bottom of our assessment form before submission, and is recorded with a timestamp at the point of submission.
Contractual Necessity: To provide the matching and platform services you have requested.
Legitimate Interests: For platform security, fraud prevention, and general analytics, where these interests are not overridden by your privacy rights.
Legal Obligation: Where processing is required to comply with applicable Canadian laws.
Consent is obtained at the point of form submission via a clearly labelled affirmation notice. Submission of the assessment form constitutes explicit, informed, and purpose-specific consent under PIPEDA. A timestamp is recorded at the point of each submission.
5. SENSITIVE INFORMATION
⚠ Updated in Version 2.0 — Consent Mechanism Added
Our matching assessment collects information that may be considered health-adjacent or sensitive in nature, including your emotional state, therapy concerns, and mental health goals. We treat this information with the highest level of care.
We commit to the following regarding sensitive information:
We will never sell your assessment responses or health-adjacent data to third parties
We will never use your assessment responses for advertising targeting purposes
We will never share your specific responses with therapists without your explicit consent
Assessment responses are used solely to generate your therapist match and improve matching accuracy
We apply appropriate technical and organisational safeguards to protect this data
Consent Mechanism for Sensitive Information: Before submitting the assessment form, all users are presented with a clear consent notice confirming that their responses — including emotional state, therapy history, mental health goals, and who they are seeking therapy for — may be considered health-adjacent or sensitive. Submission of the form constitutes explicit, informed consent to the collection and use of this information solely for the purposes described in this policy. This consent is recorded with a timestamp at the point of submission. You may withdraw this consent at any time by contacting [email protected], after which your assessment data will be deleted within 30 days, subject to any legal retention obligations.
6. HOW WE SHARE YOUR INFORMATION
We do not sell, rent, or trade your personal information to third parties. We may share your information in the following limited circumstances:
6.1 With Therapists (Consent-Based)
⚠ Updated in Version 2.0
When you submit the assessment form, you provide explicit consent for Creative Arts Connect to share a summarised matching profile with up to 2 matched therapists from our vetted network. This profile may include your preferred therapy modality, general emotional context, stated goals, and who you are seeking therapy for. It will not include your full name, contact details, or verbatim assessment responses unless you choose to share these directly with a therapist at the point of introduction.
No therapeutic relationship is created by this matching process. You are under no obligation to proceed with any suggested match. You retain full autonomy over all decisions regarding your therapeutic journey. If you wish to withdraw consent to the sharing of your profile with a matched therapist before the introduction is made, please contact us immediately at [email protected].
6.2 Service Providers
We work with trusted third-party service providers who assist in operating our Platform, including:
Email delivery services
CRM and funnel platforms (including GoHighLevel)
Website hosting and cloud infrastructure providers
Analytics providers
All service providers are contractually bound to handle your data in accordance with this Privacy Policy and applicable law.
6.3 Advertising Platforms
We use Meta Pixel and Google Analytics / Google Ads conversion tracking to measure advertising effectiveness. This may involve sharing anonymised or hashed data (such as email addresses) with Meta and Google for conversion matching purposes. This is done in compliance with their data processing terms. You may opt out via your account settings on those platforms.
6.4 Legal Requirements
We may disclose your information if required to do so by law, court order, or governmental authority, or where we believe in good faith that disclosure is necessary to protect the rights, safety, or property of Creative Arts Connect, its users, or the public.
6.5 Business Transfers
In the event of a merger, acquisition, or sale of all or part of our assets, your information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.
7. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies to enhance your experience on our Platform.
7.1 Types of Cookies We Use
Essential Cookies: Required for the Platform to function. These cannot be disabled.
Analytics Cookies: Help us understand how visitors interact with the Platform (e.g., Google Analytics).
Advertising Cookies: Used to measure the effectiveness of our ad campaigns (e.g., Meta Pixel, Google Ads).
Functional Cookies: Remember your preferences and quiz progress.
7.2 Your Cookie Choices
You may control cookie usage through your browser settings or our cookie consent banner. Please note that disabling certain cookies may affect Platform functionality. You can also opt out of interest-based advertising through:
Google: https://adssettings.google.com
Your Device Settings: Enable "Limit Ad Tracking" on mobile devices
8. DATA RETENTION
We retain your personal information for as long as necessary to provide our services and comply with our legal obligations. Specifically:
Account and contact information: Retained for the duration of your relationship with CAC plus 3 years
Assessment responses: Retained for 2 years from the date of submission
Email communications: Retained for 3 years
Analytics data: Retained in anonymised form for up to 5 years
Legal compliance records: Retained as required by applicable law
Consent records and timestamps: Retained for the duration of your relationship with CAC plus 5 years
You may request deletion of your data at any time (see Section 10).
9. DATA SECURITY
We implement appropriate technical and organisational security measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:
Encryption of data in transit using TLS/SSL
Restricted access to personal data on a need-to-know basis
Regular security assessments of our Platform
Secure data storage with reputable cloud providers
However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and applicable authorities as required by law.
10. YOUR PRIVACY RIGHTS
Under PIPEDA and applicable Canadian privacy law, you have the following rights regarding your personal information:
Right to Access: You have the right to request a copy of the personal information we hold about you.
Right to Correction: You have the right to request correction of inaccurate or incomplete information.
Right to Withdrawal of Consent: You may withdraw your consent to our processing of your information at any time, subject to legal or contractual restrictions. To withdraw consent to the use of your assessment responses for therapist matching, contact [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
Right to Deletion: You may request deletion of your personal information, subject to our legal retention obligations.
Right to Data Portability: You may request your data in a structured, machine-readable format.
Right to Object: You may object to certain types of processing, including direct marketing.
Right to Lodge a Complaint: You have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.
To exercise any of these rights, please contact us at: [email protected]
We will respond to all requests within 30 days. We may need to verify your identity before processing your request.
11. CHILDREN'S PRIVACY AND CONSENT ON BEHALF OF MINORS
⚠ Updated in Version 2.0 — Extended to All Minors
Our Platform is not directed to children under the age of 13 as independent users. We do not knowingly collect personal information directly from children under 13 without verifiable parental or guardian consent.
For users submitting the assessment form on behalf of any minor — defined as any individual under the age of 18, or as defined as a minor under the laws of their province or territory — the submitting individual confirms at the point of form submission that they are the parent, legal guardian, or authorised caregiver of that individual and that they hold the legal authority to provide consent for the collection, use, and matching of information on that minor's behalf.
Any information submitted in relation to a minor is treated with heightened sensitivity. It will not be shared with any therapist without the ongoing consent of the parent or guardian, and all matched therapist recommendations for minors will reflect therapists with verified experience working with children and young people.
If you believe we have inadvertently collected information from a child under 13 without appropriate consent, please contact us immediately at [email protected] and we will take steps to delete such information within 5 business days.
12. INTERNATIONAL DATA TRANSFERS
Creative Arts Connect operates primarily within Canada. Some of our service providers may be located in other jurisdictions, including the United States. When your data is transferred outside Canada, we ensure appropriate safeguards are in place, including:
Contractual data protection clauses with service providers
Use of service providers who comply with recognised privacy frameworks
By using our Platform, you acknowledge that your information may be processed in jurisdictions outside Canada where data protection laws may differ from those in your province or territory.
13. ADVERTISING DISCLOSURES
Creative Arts Connect runs advertising campaigns on Meta (Facebook and Instagram) and Google. In connection with these campaigns:
We use conversion tracking pixels to measure the performance of our ads
We may use hashed email matching (Customer Match / Custom Audiences) to match platform users with ad accounts for measurement purposes only
We do not use your health-related assessment data for advertising targeting
We comply with Meta's Sensitive Categories policy and Google's Healthcare and Medicines advertising policy
Ad creatives are labelled as paid advertising in accordance with applicable regulations
You may see our ads based on general interest categories, geographic location, or demographic factors — not based on your mental health information or quiz responses.
14. THIRD-PARTY LINKS
Our Platform may contain links to third-party websites, including therapist profiles or resources. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the privacy practices or content of those sites.
15. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:
Update the "Last Updated" date at the top of this policy
Post the revised policy on our Platform
Notify registered users by email where the changes are significant
Your continued use of the Platform after any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this policy periodically.
16. CONTACT US
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
Creative Arts Connect
Email: [email protected]
Website: creativeartsconnect.com
For complaints regarding our handling of your personal information that we have not resolved to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
© 2025 Creative Arts Connect. All rights reserved.
