Privacy Policy

This Privacy Policy explains how Broda-Wholeman Ltd. (“we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you use BroDA, our platform accessible at www.thewholeman.ca, our mobile application, and any related services (together, the “Platform”).

We comply with Alberta's Personal Information Protection Act (“PIPA”). We collect, use, and disclose your personal information with your consent or as otherwise authorized by PIPA. When you register an account, access features, or submit information, you provide affirmative consent to the collection, use, and disclosure of your information as described in this Privacy Policy.

This Privacy Policy applies only to information collected through the Platform. It does not apply to third-party websites, applications, or services linked to or accessible from the Platform.

We collect personal information in the following ways:

We use your information to:

• provide, operate, and improve the Platform and our content (including articles, podcasts, videos, and AI-generated summaries and takeaways);
• create and manage your account;
• enable community features such as comments, messaging, and the “Ask Anonymously” feature;
• personalize your experience, including your saved library and content recommendations;
• send you service-related communications (such as account confirmations and security alerts);
• respond to your inquiries and provide support;
• monitor for and prevent fraud, abuse, and violations of our Terms of Use;
• comply with legal obligations; and
• analyze usage trends and improve the Platform.

We will not use your personal information for purposes other than those listed above without your consent, unless permitted or required by law.

Some Platform content, including podcast summaries, takeaways, and topic guides, is generated or assisted by artificial intelligence (“AI”). We may use your Platform interactions (content you view, save, or engage with) to improve AI-generated content. We do not use your private messages or “Ask Anonymously” submissions as AI training data without your separate, explicit consent. AI-generated content may be derived from third-party content; the use of AI does not transfer ownership of that underlying content to us. AI outputs may contain errors or omissions, and we do not guarantee their accuracy or completeness.

We do not sell, rent, or trade your personal information. We share it only as follows:

• Service Providers. Trusted third parties who help us operate the Platform (hosting, analytics, email delivery, content delivery). They are contractually required to protect your information and use it only on our behalf.
• Legal Requirements. Law enforcement, regulators, or courts when required by law, court order, or legal process, or when we reasonably believe disclosure is necessary to protect rights, safety, or property.
• Business Transfers. If Broda-Wholeman Ltd. is involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction. Any disclosure will comply with applicable privacy legislation, and we will notify you following completion of the transaction or as required by law.
• With Your Consent. In any other situation where we have your consent.
• Community and Public Features. Information you share publicly on the Platform (comments, posts, public profile) is visible to other users and is not confidential.

We retain your personal information only as long as necessary for the purposes described in this Privacy Policy, considering:

• the nature and sensitivity of the information;
• the purposes for which it was collected;
• whether those purposes have been fulfilled;
• any legal, regulatory, or contractual obligations that require us to keep it; and
• whether the information is needed to establish, exercise, or defend legal claims.

We retain personal information only as long as reasonably required for legal or business purposes and securely destroy or irreversibly anonymize it once those purposes are fulfilled. If you delete your account, we will securely delete or irreversibly anonymize your personal information within a reasonable time, unless we are required by law to retain it.

Our service providers may process your personal information outside Canada, including in the United States, where data protection laws may differ. We take reasonable steps to ensure your information is protected consistently with PIPA, including through data processing agreements with appropriate safeguards.

Under PIPA, you have the right to:

• request access to the personal information we hold about you, subject to exceptions allowed by law;
• request correction of inaccurate, incomplete, or outdated personal information;
• withdraw your consent to the collection, use, or disclosure of your information, subject to legal and contractual limitations (withdrawal may affect your access to certain Platform features); and
• file a complaint with the Office of the Information and Privacy Commissioner of Alberta (OIPC) at www.oipc.ab.ca.

To exercise your rights, contact our Privacy Officer (Section 15). Requests to correct personal information are free of charge. For access requests, we may charge a reasonable fee as permitted by PIPA.

We use technical, administrative, and physical safeguards to protect your personal information from unauthorized access, loss, misuse, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you believe your account has been compromised, contact us immediately (Section 15).

The Platform contains links to and displays content from third-party websites and services. We are not responsible for their privacy practices or security. When you interact with third-party content or leave the Platform, the third party's privacy policy applies.

The Platform's community features (comments, messages, “Ask Anonymously,” community discussions) involve the following privacy considerations:

• Comments and community posts are visible to other users and the public. Do not include personal information you do not want others to see.
• Messages are private between you and the recipient, unless reported for a Terms of Use violation or where disclosure is required by applicable law or court order.
• “Ask Anonymously” submissions are not associated with your account. Do not include identifying information in your question text.
• Blocking a user prevents future interaction but does not delete content previously shared with that user.
• You can delete your comments and posts at any time. Copies may persist briefly in backups and other users' notifications.

The Platform is not directed at children under 13, and we do not knowingly collect their personal information. If you believe a child under 13 has provided us with personal information, contact us (Section 15) and we will delete it promptly. Users aged 13 to 18 should review this Privacy Policy with a parent or guardian.

The Platform does not currently respond to “Do Not Track” browser signals. You can manage tracking preferences through your browser and cookie settings (see Section 2(d)).

Where a privacy breach involves personal information under our custody or control and a reasonable person would consider there to be a real risk of significant harm to an individual, we will report the incident to the Information and Privacy Commissioner of Alberta without unreasonable delay in accordance with PIPA, and notify affected individuals as required by law or as directed by the Commissioner.

For questions, concerns, or to exercise your privacy rights, contact our Privacy Officer at: privacy@kalegal.ca

We may update this Privacy Policy from time to time. When we make changes, we will update the “Last Updated” date above. For significant changes, we will notify you through the Platform, by email, or through a mobile app notification before the changes take effect. For material changes, we will provide at least thirty (30) days' advance notice with an option to deactivate your account before changes take effect.