Last updated September 26, 2026
Scope
This notice explains how KWC Pathway to Hope, an Ontario nonprofit organization based in Kitchener, Ontario, handles information through BrightPath. It applies to the BrightPath website (brightpath.pathwaytohope.ca), including its sign-up pages, to the BrightPath app for iPhone and iPad, and to email or phone messages sent to Pathway to Hope about BrightPath.
It replaces the earlier BrightPath app privacy policy published on GitHub Pages. It does not replace a clinic’s own privacy notice, a BrightPath clinic agreement, or a data-processing agreement.
Where BrightPath is today
BrightPath is in private testing. Only people we invite use the app, through Apple’s TestFlight, and they use made-up test data. No real client or patient information is stored in BrightPath yet. Before any clinic uses BrightPath with real information, we will update this notice and put a clinic agreement and data-processing agreement in place.
Information we collect
On the public website. The public pages have no contact form, payment page, or newsletter form. They do not run analytics or advertising scripts and the site sets no first-party cookies. Cloudflare processes ordinary request information needed to deliver and protect the site, such as an IP address, browser and device information, requested pages, timestamps, and security signals.
On the sign-up pages. The pages at /auth/confirm and /start/ are used only by people a clinic or BrightPath has invited. What you enter there (your password, two-step verification set-up, your work name, and your clinic’s name and location) goes directly to BrightPath’s sign-in and database service hosted in Canada and is not stored by the website. An unfinished form is kept only in that browser tab until you finish or close it.
In the BrightPath app.
- Your account: your email address, your password (stored by the sign-in service only in a protected, hashed form), your two-step verification set-up, the work name your colleagues see, your role, and your clinic.
- Information about the people a clinic serves: names, dates of birth, contact details, health details, notes, and form answers entered by clinic staff. The app encrypts these on the staff member’s device before sending them. Our servers store them only in encrypted form.
- Information the servers need to work: account and record identifiers, roles and permissions, appointment times and statuses, clinic, location and program names, and the times records were created or changed. We use it to control who can see what and to run the schedule. We keep it free of client names and care details.
- Security records: a history of sign-ins and important actions, such as permission changes, without the content of client records.
- On your device: the keys that decrypt your clinic’s information (kept in the device’s secure storage and removed when you sign out), your app settings, and, only if you turn it on, performance measurements that stay on the device and are deleted after 14 days.
The app asks to use Face ID to unlock it; your face data never leaves the device. The app does not use your location, contacts, camera, photos, calendar, microphone, or Apple Health, and it does not send push notifications.
When you contact us. If you email or call us, we receive what you choose to share, such as your name, contact details, organization, and message. Please do not send patient records or other health information in a general message.
How we use information
We use information to sign people in and check two-step verification, to decide what each person may see and do in their clinic, to deliver encryption keys to the devices of staff who are allowed to have them, to run the clinic features of the app, to send invitation and password emails, to keep security records, to answer messages, to investigate and fix problems, and to meet legal and security obligations. We use website request information to deliver pages, prevent abuse, and keep the site available.
We do not sell personal information, show advertising, or use analytics or advertising trackers in the website or the app.
Service providers and processing locations
We use these service providers to run BrightPath:
- Supabase provides the sign-in service, database, and server functions for the app and the sign-up pages. BrightPath’s database is hosted in Supabase’s Canada (Central) region in Montréal.
- Google Workspace sends BrightPath’s invitation and password-reset emails from noreply@brightpath.pathwaytohope.ca and handles email sent to Pathway to Hope. These emails contain the recipient’s email address and a sign-in link, never client information.
- Cloudflare provides website delivery, DNS, and security services.
- Apple distributes test versions of the app through TestFlight. Apple processes testers’ names and email addresses, and any feedback or crash reports testers choose to send. Apple also provides Face ID and device security features.
- Telecommunications providers handle phone calls to us.
These providers may process information in Canada, the United States, or another country where they or their subprocessors operate, and information there may be subject to local law. Client information in the database is stored in Canada, in encrypted form. We remain responsible for personal information under our control and choose providers according to the information and service involved.
How client information is protected
Client names, dates of birth, contact details, health details, notes, and form answers are encrypted on the staff member’s device, and each clinic has its own encryption key. The app requires two-step verification for every account, and our servers give a clinic’s key only to devices of staff whose role allows it, after two-step verification.
BrightPath keeps a protected backup copy of each clinic’s key so that new staff devices can receive it. Pathway to Hope controls that backup, so this is not “zero-knowledge” encryption. Before any real information is stored, the key that opens the backup must move into a dedicated key vault with two-person control.
Retention
Website security and delivery logs are kept according to operational settings and provider requirements. Messages to us are kept only as long as needed to answer them, keep an appropriate business record, resolve disputes, protect the service, or meet legal obligations.
While BrightPath is in private testing, test accounts and made-up test data are kept for as long as testing needs them and can be deleted on request. Retention periods for real clinic records will be set in the clinic agreement, in line with the law that applies to the clinic, before any real information is stored.
Clinic and patient information
When a clinic uses BrightPath for real client records, the clinic is responsible for those records (for example, as the health information custodian under Ontario’s PHIPA), and Pathway to Hope provides the technology on the clinic’s behalf as its service provider. The clinic agreement will describe each party’s role, data location, access, retention, deletion, breach response, and subcontractors.
If your question concerns a record held by a clinic, contact that clinic first.
Access, correction, and complaints
You may ask whether Pathway to Hope holds personal information about you, request access, ask for a correction or deletion, or raise a concern about how it was handled. We may need to verify your identity and may be unable to provide information where the law permits or requires us to withhold it.
Contact the Privacy Lead at privacy@pathwaytohope.ca or call 1-888-861-8830. You may also contact the Office of the Privacy Commissioner of Canada or, for health information held by an Ontario clinic, the Information and Privacy Commissioner of Ontario.
Safeguards
We use administrative, technical, and physical safeguards suited to the information and its sensitivity, including encryption on the device, encrypted connections, two-step verification, role-based access checked by our servers, and data storage in Canada. No online service can promise absolute security. If we confirm a privacy incident, we will respond according to the applicable law, the information involved, and any clinic agreement.
Children and youth
The website and the app are for clinics and their staff, not for children. A clinic may record information about the children it serves; that information is protected as described above and is the clinic’s responsibility. A parent or guardian should contact us before a child sends personal information to us by email or phone.
Changes to this notice
We will update the date at the top and revise this page when the website, the app, our providers, or our legal obligations change in a way that affects this notice. Material changes for clinics will also be addressed through the agreements and notices that apply to them.
Contact
KWC Pathway to Hope, Privacy Lead
701-310 Queen Street South, Kitchener, Ontario N2G 1K2
privacy@pathwaytohope.ca · 1-888-861-8830