Data Protection, Cookie and Privacy Policy

Protecting the privacy and information of our clients, candidates, and external stakeholders is of the utmost importance. With attention, focus, and care, Comeback Catalyst is responsible for the personal information entrusted to us to help individuals launch their businesses and organizations grow. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information in compliance with applicable privacy laws, including PIPEDA (Personal Information Protection and Electronic Documents Act), Law 25 (Quebec), BC PIPA (Personal Information Protection Act), and GDPR, as well as our practices when working with third-party vendors. By using our services, you consent to the practices described in this policy.

Now, let’s get to the details.

  1. Personal Information Collection: Except as otherwise set out below, Comeback Catalyst is the Controller of personal information (“Controller” within the meaning of applicable data protection legislation). For greater clarity, Controller means the entity that decides why and how personal information is processed. As the Controller, Comeback Catalyst will alone or jointly with agreed-upon partners determine the purposes and means of processing your personal data.

We collect personal information that is relevant to providing our business development and mentorship services. This could include but is not limited to:

  • Contact details (name, email, phone number, address)

  • Social media and online presence (LinkedIn, Facebook, X (formerly Twitter), etc.)

  • Employment history

  • Education background

  • Professional qualifications

  • References

  • Any other relevant information shared with us during the program application process, such as pronouns and city/country of residence.

Applicants and Program Participants: We use your personal information when applying and/or participating in the Comeback Catalyst program and/or when providing business mentorship and support services. These services include, but are not limited to, business development coaching, financial literacy education, strategic planning, leadership development, and networking opportunities.

By innovating at scale and ensuring our tools meet the needs of our participants, Comeback Catalyst will fulfill our vision: to support formerly incarcerated individuals in launching sustainable businesses and fostering economic independence.

  1. Personal Information We Collect as a Participant: We collect and process personal information about you such as:

  • Identification information – name, contact information (including home address, home phone number and mobile phone number), citizenship and country of residence, date of birth, digital signature, and languages spoken.

  • Business and professional background – work history, business experience, skills, educational background, and other relevant information (such as interview notes and personal data included in the application process).

  • Financial and business information – personal data relating to your business idea, financial literacy, and funding needs.

  • Government-issued identifiers – we may process government-issued identifiers including (without limitation) tax identification numbers, business registration details, and other required documentation only as legally necessary.

  • Photographs, audio, and video footage – when participating in business development events, mentorship sessions, or program meetings, we may process photographs, audio, or videos of you. If an event is being recorded, we will seek consent in advance and provide an opportunity to opt out.

  1. Use of Personal Information: We use your personal information for the following purposes:

  • To provide our program services, including mentorship, workshops, and business development resources.

  • To match your skills and business ideas with aligned mentorship and funding opportunities.

  • To communicate with you regarding program activities, coaching, and training sessions.

  • To comply with legal obligations and regulatory requirements.

  • To improve our services and tailor them to your preferences.

  1. Disclosure of Personal Information: With your consent, we may disclose your personal information to:

  • Business mentors, investors, and funding partners aligned with your entrepreneurial journey.

  • Third-party service providers who assist us with various functions (e.g., program management platforms, business development tools, etc.).

  • Legal authorities and regulatory bodies as required by law.

  1. How Your Information is Shared: Your information might be shared:

  • With Comeback Catalyst partners and stakeholders providing business and financial support.

  • With third-party providers of IT-related services (e.g., cloud storage and data security services).

  • With third-party providers of professional services (e.g., legal and financial advisors).

  • With public authorities if legally required.

We may also disclose your personal information to third parties:

  • In the event that we merge, acquire, or divest business operations, your personal information may be transferred as part of the process.

  • If required by law enforcement authorities, courts, or regulatory bodies.

When we share your personal information as described above, it may be transferred outside of Canada, depending on program collaborations or partnerships. In such cases, we will ensure that adequate levels of data protection are in place.

  1. Your Rights: You have the right to:

  • Access the personal information we hold about you.

  • Rectify inaccuracies in your personal information.

  • Withdraw consent at any time.

  • Request that all personal information stored by Comeback Catalyst be deleted.

  • Request erasure of your personal information, subject to legal obligations.

  • Object to the processing of your personal information.

  1. Security: We implement technical and organizational measures to protect your personal information from unauthorized access, loss, misuse, or unintended disclosure. However, no data transmission over the internet can be guaranteed to be 100% secure.

  2. Retention: We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including any legal, accounting, or reporting requirements. Comeback Catalyst maintains record retention schedules to ensure that personal information is retained only as long as reasonably necessary.

  • Comeback Catalyst will delete participant data within one month of a participant’s request.

  • Comeback Catalyst will delete financial or business data after seven years, following program completion or discontinuation.

  1. Changes to Privacy Policy: We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. The most current version will be posted on our website, and the date of the latest revision will be indicated.

  2. Acknowledgment and Questions?: If you have any questions or concerns about our privacy practices, wish to exercise your rights, or need to contact us for any reason related to your personal information, you can reach us at:

Lucy Cullen
CEO, Comeback Catalyst

By using our services, you consent to the practices described in this Privacy Policy.