Privacy Policy

Last Updated: January 2026

1. Introduction

This Privacy Policy describes how Emergence Counselling & Wellness (“we”, “us”, “our”) collects, uses, discloses, and protects personal information in connection with the “Emergence Counselling Content Manager” application, in compliance with British Columbia’s Personal Information Protection Act (PIPA), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and the ethical standards of the BC Association for Clinical Counsellors (BCACC) and the Canadian Counselling and Psychotherapy Association (CCPA).

2. Privacy Officer

Privacy Officer: Valentina Chichiniova, Registered Clinical Counsellor

For privacy-related inquiries or complaints, please contact:

3. Information We Collect

This application is used for managing social media content for Emergence Counselling & Wellness Inc. The application may collect and store the following types of information:

• Content Data: Social media posts, content drafts, scheduling information, and related metadata generated or entered by you
• Technical Data: API access tokens (stored locally and encrypted), application settings, and usage data
• Account Information: Social media account identifiers and access tokens (only when you authorize social media integration)

We do NOT collect: Client information, personal health information, or any data related to counselling services. This application is separate from clinical record-keeping systems.

4. Purpose of Collection

Personal information is collected and used solely for the following purposes:

• Generating and managing educational content for social media platforms
• Scheduling and organizing social media posts
• Creating images and media for social media content
• Posting approved content to authorized social media accounts (when you choose to use this feature)
• Improving the application’s content generation capabilities through tone learning (using anonymized content patterns, not personal data)

5. Consent

How Consent is Obtained: By using this application, you provide implied consent for the collection and use of information as described in this policy. For social media integration, explicit consent is obtained through the authorization process.

Withdrawing Consent: You may withdraw consent at any time by:

• Discontinuing use of the application
• Revoking social media API access through your social media account settings
• Deleting stored data within the application
• Contacting the Privacy Officer to request data deletion

6. Use and Disclosure

Use of Information: Personal information is used only for the purposes stated in Section 4. We do not use your information for any other purposes.

Disclosure: We do not sell, rent, or share your personal information with third parties except:

• When required by law or legal process
• When necessary to protect rights, property, or safety
• With third-party service providers who assist in application functionality (see Section 7), under strict confidentiality agreements

7. Third-Party Services

This application uses the following third-party services, each with their own privacy practices:

• OpenAI API – For AI-powered content generation. Content is generated based on your input. OpenAI’s privacy policy applies to their processing. We do not send personal client information to OpenAI.
• Pexels API – For accessing free stock images. Images are downloaded and used locally. Search queries may be sent to Pexels, but no personal information is shared.
• Facebook/Instagram APIs – For posting content to your social media accounts. These APIs are only accessed when you explicitly authorize. Facebook/Meta’s privacy policy applies to their services.

Data Location: Third-party services may process data outside of Canada. We ensure that any data shared with third parties is done so in compliance with applicable privacy laws.

8. Data Storage and Retention

Storage: All content, posts, and data generated by this application are stored locally on your device or server within Canada, where possible. We implement appropriate technical and organizational measures to protect your data.

Retention: Data is retained only as long as necessary for the purposes stated in Section 4, or as required by law. You may delete data at any time through the application interface.

Disposal: When data is no longer needed, it is securely deleted using industry-standard methods to ensure it cannot be recovered.

9. Security Safeguards

We implement appropriate security measures to protect personal information against unauthorized access, use, disclosure, alteration, or destruction:

• Technical Safeguards: Encryption of sensitive data (API tokens), secure data transmission, and access controls
• Administrative Safeguards: Limited access to data, staff training on privacy, and regular security reviews
• Physical Safeguards: Secure storage of devices and servers hosting the application

Breach Notification: In the unlikely event of a privacy breach that poses a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by law.

10. Social Media Integration

When you choose to integrate social media accounts:

• You must explicitly authorize the application to access your social media accounts
• Only the content you approve is posted
• Access tokens are stored locally in encrypted format
• You can revoke access at any time through your social media account settings
• We access only the minimum information necessary for posting content (Page ID, posting permissions)
• We do not access, store, or use personal information from your social media accounts beyond what is necessary for the posting function

11. Your Rights

Under BC’s PIPA and Canada’s PIPEDA, you have the right to:

• Access: Request access to your personal information held by us
• Correction: Request correction of inaccurate or incomplete information
• Withdrawal of Consent: Withdraw consent for collection, use, or disclosure of your information (subject to legal or contractual restrictions)
• Complaint: File a complaint with the Privacy Officer or the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated

To exercise these rights, contact the Privacy Officer using the contact information in Section 2.

12. Accuracy

We make reasonable efforts to ensure that personal information is accurate, complete, and up-to-date. You are responsible for updating your information as needed through the application interface.

13. Openness and Transparency

This privacy policy is publicly available on our website. We are committed to transparency about our privacy practices and will provide additional information upon request.

14. Challenging Compliance

If you have concerns about our compliance with this privacy policy or applicable privacy laws, you may:

• Contact our Privacy Officer (see Section 2)
• File a complaint with the Office of the Privacy Commissioner of Canada
• File a complaint with the Office of the Information and Privacy Commissioner for British Columbia

15. Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or applicable laws. The updated version will be posted on this page with a new “Last Updated” date. We encourage you to review this policy periodically.

Material Changes: If we make material changes to this policy, we will notify you through the application or by other reasonable means.

16. Compliance with Professional Standards

This application and its content generation comply with:

• BC Association for Clinical Counsellors (BCACC) Code of Ethical Conduct and Standards of Clinical Practice, including Standard 10 (Privacy and Confidentiality) and Standard 7 (Virtual Practice & Digital Technologies)
• Canadian Counselling and Psychotherapy Association (CCPA) Code of Ethics, including requirements for confidentiality and privacy protection
• British Columbia Personal Information Protection Act (PIPA)
• Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)
• British Columbia advertising regulations for healthcare professionals

All generated content is reviewed for ethical compliance before posting, ensuring adherence to BCACC Standard 11 (Marketing & Advertising) and CCPA advertising standards.

17. Contact Information