ICINFRASTRUCTURE LEARNING SERVICES - PRIVACY POLICY

Version: 3.0

Last Updated: March 23, 2026

ic Infrastructure Corporation (“we”, “us”, and “icInfrastructure”) provides consulting, coaching, and training to public and private sector infrastructure owners and managers to support them with their infrastructure asset management and business improvement efforts (the “learning services” or “services”). We provide these learning services to organizations such as towns, cities, and other governmental entities, professional and industry associations, as well as private sector entities (our “clients”). A Client may enroll its own employees, members, or volunteers in our learning services, or may fund, sponsor, or make programs available to participants from multiple organizations or jurisdictions, such as staff from different cities or agencies. We help train and coach our clients’ employees, members, volunteers, and program participants, as well as other individuals seeking to improve their infrastructure asset management competence (“you”, “your” or “trainees”) through our online or in person training programs (“programs”) and courses (“courses”). 

This privacy statement is designed to help you understand how we collect, use, secure, and share personal information collected while providing our learning services.

What information do we collect? 

This Privacy Policy applies primarily to personal information collected through our online learning platform and related digital services. Information collected during online events, inperson training, workshops, or other offline interactions is handled in a manner consistent with this Privacy Policy, unless a separate privacy notice is provided in connection with a specific event or engagement.

We are committed to data minimization and collect only the personal information that is reasonably necessary to provide our learning services. In most cases, this includes limited contact and account information such as name, email address, organizational affiliation, and course participation details. 

We do not seek to collect sensitive personal information (such as government‑issued identification numbers, health information, or financial account details) through our learning platform. However, in limited circumstances, personal information that may be considered sensitive could be provided by participants voluntarily (for example, through open‑text responses, discussions, or video participation), or where required to support accessibility, accommodation, or specific program requirements, and where permitted by law.

When you enroll as a trainee in one of our programs or courses, we collect basic contact and account profile information, such as your name and email address, which is required to administer your participation in the learning services.

We may also collect, from you or from our client where appropriate, additional background information such as your job role, skills, employer, location, experience, and education. This information is used to support learning delivery, assess progress, and, where applicable, enable optional networking or cohortbased learning features.

You may choose not to provide certain optional background information or may opt out of having this information shared with other program or course participants for networking purposes, where such features are offered. However, certain information is required to participate in clientsponsored programs and to meet reporting, certification, or compliance requirements. 

During the period you interact with our learning services, we will collect information about your use of our offerings and our platform, including the content and sessions you access, your engagement with them, and completion information. We may collect and compile your responses to quizzes and similar assessments. 

Where a program or course is sponsored or funded by a Client, we may collect, process and use personal information as a service provider on behalf of that Client. In such cases, the sponsoring Client may have primary responsibility for determining the purposes of collection, use, retention, and disclosure of personal information in accordance with applicable law. We may also send you electronic communications on their behalf regarding their offerings and registrations.

We may send you emails related to your enrollment, participation, and use of our learning services, including program updates, course information, service announcements, and surveys related to your learning experience.

Where permitted by law, we may also send you promotional communications about new or additional programs, courses, events, or services offered by icInfrastructure that may be relevant based on your prior participation or engagement with our learning services. You may unsubscribe from promotional or marketing communications at any time using the unsubscribe link included in those emails.

Our learning platform and other technologies used in during the provision of our services may include features permitting you to post messages to others, engage in a discussion forum, and post photos, electronic files, documents, and other similar content. These features will often permit everyone participating in the program or course to see your posts. If your program or course involves virtual training, coaching or consultations your image, likeness, voice, comments, ideas, actions, and/or statements will also be visible to all those attending the virtual session and to anyone who may subsequently view a recording of that session. You should not treat any of these written, verbal, video, or other engagements as private. Participants are encouraged not to share sensitive or confidential personal information through discussion forums, chat features, or other collaborative tools and should share only what is reasonably necessary for participation in the learning activity.

Notice and Consent

Where appropriate, we may rely on our clients to provide you with any notice or obtain consent as may be required by them for their provision of your information to us. When you create your user account and/or profile with us, we will ask you to acknowledge this Privacy Statement so you understand how we generally collect, use, and share your information. In some cases, we may also request your express consent or provide you with notice for other purposes as permitted or required by law. 

When you provide us with personal information to subscribe to a service on our site, make a purchase, or participate in a program, event, course, or digital product, we collect and use that information for the identified purposes, in accordance with this Privacy Policy and as permitted by applicable law.

You may receive transactional communications related to your enrollment and participation in our services. You may also receive marketing communications where permitted by law, and you may unsubscribe from marketing communications at any time using the unsubscribe link included in those emails.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent at anytime, by contacting us at [email protected] 

How do we use and share your information?

When we are engaged to provide learning services for trainees, we use the information of those trainees to help us deliver those services. For example, we will use your user account profile information to identify you and track your participation and progress in our services. We may share high level results and individualized information about your participation and progress with those clients that have engaged us to provide learning services to you so they can assess the service, understand competencies, and develop further training and resource plans. We will also use this information to demonstrate to our clients skills learned, proficiency, and progress, and to assess and report on the success of the services. We routinely report or provide analysis to our clients regarding individual and group competencies and planning. 

We will also use the information about your interaction with our services, your use of our offerings and our platform, including the content and sessions you access and how you engage with them, as well as completion information, to help us assess and improve the services we offer, understand how people use them, as well as understand and demonstrate learning progress and achievements. We may use aggregated data to demonstrate how our services assist clients and individuals. 

In limited circumstances, we may wish to use video, audio, photographic, textual, or other materials collected during the provision of the learning services to develop additional educational offerings or marketing resources. Where we wish to use identifiable content for marketing, advertising, or promotional purposes related to our learning services, we will clearly describe the intended use and obtain your express consent in advance. We will not use identifiable content from clientsponsored programs for marketing or promotional purposes without explicit permission from both the participant and the sponsoring Client where appropriate.

Where a program or course is sponsored, funded, or made available by a client organization—such as a municipality, government entity, association, or industry body—we may provide designated representatives of that client with registration status, participation records, completion status, and related progress information for purposes such as training administration, reporting, certification tracking, funding verification, program evaluation, or compliance.

In these circumstances, we collect and process personal information as a service provider on behalf of the sponsoring client, and the client may have primary responsibility for determining the purposes of collection, use, retention, and disclosure of personal information in accordance with applicable law. In multiorganization or associationsponsored programs, reporting will generally relate only to participants affiliated with that client or will be aggregated or deidentified, unless otherwise agreed and permitted by law.

If you have questions about how your personal information is handled in connection with a specific clientsponsored program or course, we encourage you to contact the sponsoring client directly.

As part of our professional learning community, we may facilitate email introductions between peer participants who share similar roles, interests, or challenges. Participation is voluntary, and you may decline or opt out of such introductions at any time.

Nothing in this policy is intended to limit how and what information we may collect, use, or disclose in accordance with and as permitted by law. 

Use of Automated Tools and AI

We may use automated tools, including artificial intelligence, to analyze trainee participation, engagement, and progress within our programs and courses. These tools help us provide insights to improve learning experiences, assess skill development, and generate aggregate reports for our clients or program partners. No AI tools are used to make decisions about you outside of the context of learning analytics and program assessment. All data processed through these tools is handled in accordance with this Privacy Policy and applicable privacy laws.

Disclosure

We may disclose your personal information if we are required by law, such as in response to a court order or an investigation.

Our service providers

Our team and our software tools work remotely in a fully virtual environment to support clients around the world. We expertly use several online communication and collaboration platforms. A current list of key third‑party service providers used to support our learning services is available upon request. These providers are engaged solely to perform services on our behalf and are subject to contractual obligations regarding confidentiality, security, and permitted uses of personal information.

In general, our service providers will only collect, use, and disclose your information to allow them to perform the services they provide to us.  Some of the service providers we use are independent providers and have their own terms and privacy polices which govern the collection, use, and disclosure of the information they collect through use of the service.  

Direct service providers

Our programs and courses and learning services sites are hosted by Thinkific Labs Inc. (“Thinkific”). They provide us with the online learning content creation and learning management platform on which we primarily provide our services to our clients. Your information is stored by Thinkific and is managed through the general Thinkific application. They store your data on a secure server behind a firewall. You are invited to review Thinkific’s terms and privacy policy here

Payment

If you make a purchase on our site, we use a third-party payment processor such as Stripe or PayPal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

The information shared by you with those platforms and applications is governed by those party’s privacy policies and terms of service and are no longer governed by this Privacy Policy or our Terms of Use. The terms and privacy policies of those platforms are available through the services, and we encourage you to review them when you log in and periodically afterwards. We are not responsible for any of the collection, use, or disclosure of personal information practices of those platforms.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.

Indirect service providers

In collaboration with us, our clients may also choose to engage in some of the training, coaching, or consulting services through a third-party video conferencing platform such as Zoom, Google Meet, MS Teams, Citrix Webex, or others. The terms and privacy policies of those platforms are available through the services, and we encourage you to review them when you log in and periodically afterwards. We are not responsible for any of the collection, use, or disclosure of personal information practices of those platforms. 

Once you leave our platform, are redirected to a third-party website or application, or use a separate platform for video conferencing, the information shared by you with those platforms and applications are no longer governed by this Privacy Policy or our Terms of Use. We will not typically provide any of your information to those third-party platforms.   We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

In some cases, icInfrastructure or our clients, may record the video conferencing session for future uses. In such case, you may be provided with additional notice in advance or at the time of the recording, or you will be asked for consent as required by law. icInfrastructure’s use of the recording will be governed by the notice or consent provided at the time and this privacy policy. For additional terms and conditions related to video recordings see also the icInfrastructure Learning Services Terms of Use.

Internal business systems

In the course of providing our learning services and operating our business, we may store and process limited personal information within our internal business systems, such as email, document management, collaboration, customer support, and administrative tools. These systems are used for purposes such as program administration, communications, reporting, client support, billing, and record‑keeping. These systems are operated by reputable service providers and are subject to appropriate security and confidentiality measures consistent with this Privacy Policy.

 

Where is your information stored? 

We are based in British Columbia, Canada and our learning platform and data hosting service provider is also located in British Columbia, Canada. As such, we and your data are subject to the laws of British Columbia and Canada, including privacy laws such as the Personal Information Protection Act (B.C.) and the Personal Information Protection and Electronic Documents Act (Canada). Canada is recognized by the European Data Protection Authorities as a jurisdiction which provides adequate privacy protections to GDPR and thus for the international transfer of data. 

Indirect service and business system providers may be located in or have facilities that are located in a different jurisdiction than either you or us. Just as those platforms have their own privacy policies pursuant to which your information will be handled by them, your information shared on those platforms may also become subject to and accessible in accordance with the laws of the jurisdiction(s) in which that service provider or its facilities are located. 

Security

We take reasonable precautions to help ensure your personal information is kept secure and is only used for the purposes for which it was collected. We have implemented technical, administrative, and organizational measures to help ensure that access to your information is secure and limited to appropriate purposes. Our learning platform provider, Thinkific, helps to provide security for our platform and follow industry best practices to help protect against loss, inappropriate access, use, disclosure, alteration, or destruction.

We note that no method of transmission over the internet or electronic storage is 100% secure and cannot guarantee complete security. 

You will be given or asked to create a unique user ID and temporary password to access the learning platform. Your user ID and password are for your personal use only. You are responsible for maintaining the confidentiality of your user ID and password and are responsible for all activities that occur under your ID and password. You agree to notify us immediately of any unauthorized use of your user ID or password or any other breach of security you become aware of. We will not be liable for any loss or damage arising from your failure to protect your user ID, your password, or other access to your user account/profile arising from your own actions.

Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide our learning services, support program delivery and completion, meet reporting and certification requirements, comply with contractual obligations to our clients, and satisfy applicable legal, regulatory, or audit requirements.

Trainee account and participation information is generally retained for the duration of a program or course and for a reasonable period thereafter to support reporting, completion verification, certification validation, and client recordkeeping needs.

Where we provide learning services on behalf of a client organization, retention periods may be determined by our contractual arrangements with that client, and the client may have primary responsibility for establishing retention schedules in accordance with applicable law.

When personal information is no longer required, we securely delete, anonymize, or otherwise dispose of it in accordance with applicable laws and reasonable business practices.Some of the platforms and service providers we use may have their own retention schedules for the data they process. We retain personal information only for as long as necessary to provide our services, meet contractual obligations, support reporting or certification requirements, or comply with applicable legal obligations.

Your information rights

You may have various rights in accordance with the law to access, correct, amend, delete, or port your information.  

If you would like to exercise any of these rights, we recommend you first access your user account information and take the steps that are available to you. Further, we encourage you to contact our client, where applicable, as in most cases our client will have control over the information we collect on their behalf.  

In the event you have a concern or are not able, through the methods above, to access, correct, amend delete, or port the information you would like about yourself as the case may be, please contact us at: [email protected] so we can assist you. We will respond to your request in accordance with an as required by law.  

There may be instances where your rights to access, correct, amend, delete, or port your information are limited and we may not or cannot comply with your request in whole or in part. If so, we will explain that to you. In some cases, we may not be able to comply due to a contractual obligation, it would infringe on the rights of others, or we may not be able to provide further or certain services, including the offerings on our platform. 

If you have any concerns about our information handling practices, please contact us at: [email protected]

If you are not satisfied with our response to a privacy concern, you may have the right to make a complaint to the Office of the Information and Privacy Commissioner for British Columbia or, where applicable, the Office of the Privacy Commissioner of Canada.

Cookies and web analysis tools notice

Our platform uses cookies and similar tracking technologies. These cookies will recognize your device and provide you with a personalized experience. This information can be used to track your session on our website and platform. It helps us to customize our website content and platform offerings, including programs and courses you are taking, for you as an individual.  

If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to restrict cookies on your browser. Certain aspects of our website or platform may not be useable by you if you do not allow cookies for them. 

We may use web analysis tools such as Google Analytics to measure and collect information about engagement, preferences and your use of our website and platform. Where required by applicable law, we will obtain your consent for the use of cookies or similar tracking technologies, including through cookie consent banners or preference tools. You may manage your cookie preferences through your browser settings or other available controls.

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Age of Consent

Our learning services are intended for adult learners and professional audiences. By using this site, you represent that you are at least the age of majority in your jurisdiction. We do not knowingly collect personal information from minors, except where participation is explicitly authorized by a client organization and permitted by applicable law.

Changes to the policy

We may modify and update this privacy policy at any time, so please review it routinely. Changes and clarifications will take effect immediately upon their posting on the website or platform. If we make material changes to this policy, we will notify you here that it has been updated, so that you may be aware of how we are handling your personal information.

In the event icInfrastructure is acquired or merged with another organization, your information may be transferred to that entity so they may continue to provide these services. 

Contact us

If you have any questions or concerns about our personal information handling practices or would like to make an inquiry, please contact us at: [email protected]