Unifocus Privacy Notice

Privacy rights for Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia residents

Canadian Privacy Rights

Information on Canadian privacy laws
Rights under Canadian privacy laws

Additional Information for Residents of the European Economic Area (EEA) and the United Kingdom (UK)

Legal basis for data processing
GDPR rights
Data transfer and retention policies

Last Updated: March 19, 2026

Download Privacy Notice

Our Privacy Notice Has Recently Changed.

Your privacy is important to Unifocus and our subsidiaries and affiliates (collectively, “Unifocus,” our,” “us,” or “we”). This Privacy Notice (the “Notice”) explains the types of information we may collect from you or that you may provide when you visit the website https://www.unifocus.com/ (our “Website”), use any Unifocus products, services, and applications that are made available to you through the Website and other platforms, or otherwise communicate with us (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Notice does not apply to any products, services, websites, mobile applications, or content (including advertising) offered by third parties or that may be linked to or from the Services. Data collected by these third parties is covered by their own privacy notices.

Please read this Notice carefully. If any term in this Notice is unacceptable to you, please do not use our Services or provide us with any personal information.

In this Notice, when we talk about “Personal Information,” we mean any information that is related to an identified or identifiable natural person, or as otherwise defined by applicable data protection law.

Unifocus is the data controller, as the term is defined by applicable data protection laws, of the Personal Information that we collect from you when you use our Services, such as survey data, support requests, Personal Information within our mobile application, or information in a contact form. This Notice only applies to Personal Information that is collected by Unifocus when you use the Services.

If you engage with our Services as part of your employment, and your employer or another third party uses Unifocus’s Services (“Unifocus Client”), the Unifocus Client acts as the data controller for any of your Personal Information it provides to us. In this scenario, we act as a data processor under applicable data protection laws, using your Personal Information solely to deliver the service to the Unifocus Client as required. Unifocus Clients are responsible for maintaining their own privacy policies and for ensuring that they have obtained the necessary authorizations and consents for any collection, use, and disclosure of Personal Information, including by Unifocus. Any Personal Information that is provided to us by a Unifocus Client is governed by the Unifocus Client’s own privacy policy, as that Unifocus Client is the data controller of that information.

1. Your Information We Collect

Depending on your relationship with us, we may collect the following categories of Personal Information from you:

Personal details: Name, email address, telephone number, company name, job title, and other professional and employment information;
Account information: Account login credentials such as username and password;
Financial information: Billing and payment information (e.g., credit card or ACH account information);
Device and other automatically collected information: IP address, browsing history, search history, and information regarding your interactions with a website, application, or advertisement. For more information, see “Information We Automatically Collect About You” below;
Views and opinions: Feedback, survey responses, and other information included within your interactions with us or otherwise provided via the Services; and

Communications: We may record our communications including chat messages and phone or video calls, such as when you utilize our chatbot or provide us with feedback.
Employee and Job Applicant Information: If you are an employee or have applied for a job or other position with us, we may also collect employment information such as your name, resume/CV, educational background, language and other skills, work experiences, and job references.

2. How We Collect Your Information

Information We Collect Directly From You

We may collect Personal Information that you provide to us when you use our Services or interact with us. For example, we may collect information when you browse through the Website, register or create an account, make an information request, utilize our chatbot, or when you otherwise interact with us and provide your information via our Services.

Information We Automatically Collect About You

As with many websites, when you interact with our Website, we may use automatic data collection technologies to collect and log certain information about your equipment, browsing actions, and patterns, including details of your visits to our Website (e.g., traffic data, logs, other communication data, and resources that you access and use on our Website), information about your computer, mobile device, and internet connection (including your IP address, operating system, and browser type), and location data, which we collect to ensure you reside in a jurisdiction in which you are eligible for using our Services, to comply with relevant laws, and for fraud prevention purposes.

Cookies

The technologies we use for automatic data collection include browser cookies, flash cookies, and web beacons. We may store cookies (e.g., locally stored objects) on your device when you use our Website [1] . These technologies help us speed up your future activities and improve your experience by remembering the information that you have already provided to us. Third parties operating on our behalf may also use these technologies to provide us with anonymous data and information regarding the use of our Website. For more information on how you can block or delete these technologies from your device and our practices related to opt-out preference signals, please see Section 11 “Other Choices.”

We use Google Analytics to collect information on your use of our Website. Google Analytics collects information such as how often users visit our Website, what pages they visit, and other websites visited prior to or after coming to this Website. The data collected through these tools is not tied to other Personal Information that we collect about you. To know more about data collected by Google Analytics, visit https://policies.google.com/privacy.

You may prevent the use of Google Analytics by disabling cookies. You may also prevent Google Analytics from recording the data generated by the cookie and pertaining to your use of our Website (including your IP address), or processing this data, by downloading and installing the browser plug-in available through Google at the following link: https://tools.google.com/dlpage/gaoptout.

Information We Collect From Other Sources.

We may collect Personal Information about you from our affiliates and our partners and their service providers and contractors. For example, this may include your current job position, business address, company name, and position title provided by your employer. We also may obtain information you have made publicly available, including from websites and online services you use, consumer research platforms, and/or business contact databases.

3. How We Use Your Information

We may collect Personal Information for the following purposes:

Provide our Services and its contents to you;
Provide or improve the Services requested by you, including in the context of your business relationship with us, and perform our contractual obligations;
Fulfill or meet the reason you provided the information (e.g., to respond to your email or request for information);
Communicate with you about our Services or to provide you with information or marketing materials (e.g., promotional offers) that may be of interest to you, including through our use of targeted advertising;
Send you transactional or relationship messages, such as receipts, account notifications, customer service responses, and other administrative messages;
Monitor and analyze trends, usage, and activities in connection with the Services;
Comply with the law, and protect or defend our interests or the interests of our customers or users of our Services if permitted by law or required to do so by law, court order, or government regulations, or where we believe such action is necessary;
Help maintain the safety, security, and integrity of our Services, products and services, databases, other technology assets, and business;
System administration and to monitor the use of our Services;
Any other purpose disclosed by us when you provide the information or with your consent; and
Disclose to third parties for the performance of services provided to us, including third-party providers of services related to the operation and management of our Services, or in connection with the administration and support of the activities noted above.
[Please note that we do not collect, use, or sell Personal Information for the purpose of training large language models.]

4. With Whom Do We Disclose Your Information

We may disclose information about you as follows and as otherwise described in this Notice or at the time of collection:

With companies and vendors that perform services for us, including email and text [1] messaging service providers, payment processors, fraud prevention vendors, analytics providers, advertising partners, and other service providers;
To accountants, auditors, lawyers, and other outside professional advisors to Unifocus, subject to appropriate contractual obligations of confidentiality;
Where required by law, court order, or subpoena if we believe disclosure is in accordance with, or required by, applicable law or legal process or where necessary to prevent, detect, or prosecute criminal offenses, or to protect the rights, property, and safety of Unifocus or others;
In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
Between and among Unifocus and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
With your consent or at your direction.

Please note we may disclose certain categories of Personal Information including identifiers and internet or other similar network activity to show you targeted advertisements on third-party properties and to expand the reach and effectiveness of our own marketing campaigns. These activities may be considered “sales,” “sharing,” or “targeted advertising” under certain state laws.

We may also process and disclose information to third parties if the information has been de-identified or aggregated in a way so it cannot be used to identify you.

5. How We Protect Your Information

We use reasonable security measures to protect your Personal Information. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

6. Data Retention

We retain your Personal Information so long as necessary for the purposes for which it was collected or otherwise processed. When determining the retention period, we take into account criteria, such as the type of services requested by or provided to you, the nature and length of our relationship with you, use of our Services, and the impact on the Services functionality if we delete your Personal Information.

7. Children

The Services are not directed towards children. We do not knowingly collect Personal Information from children under the age of 13 (or 16 where applicable by law) through the Services. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Notice by instructing their children to never provide Personal Information through the Services without their permission. If you have reason to believe that a child under the age of 13 (or 16, where applicable) has provided Personal Information to us, please contact us using the methods described in Section 10 “How to Contact Us,” and we will endeavor to delete that information from our databases.

8. Links

The Services may contain content, services, advertising, and other materials that link to external websites. We do not endorse and are not responsible for the content of any such external website. Please refer to the terms of use and privacy notices of the external website for more information.

9. Changes to This Notice

This Notice is effective as of the date stated at the top of this Notice. We may change this Notice from time to time. Your access of the Services after such change will be deemed acceptance of the new Notice.

10. How to Contact Us

If you have any questions or concerns about our privacy practices or about exercising your rights, you may send an email to privacy@unifocus.com or call us at (972) 512-5000 [1] . You may also write to us at: 511 E. John Carpenter Freeway, Suite 410, Irving, TX 75061.

As described at the beginning of this Notice, we may process Personal Information for our Unifocus Clients or other third parties. To this end, if not stated otherwise in this Notice, we process such Personal Information as a data processor on behalf of our Unifocus Clients (and their affiliates) or other third parties who are the data controller of the Personal Information. We are not responsible for and have no control over the privacy and data security practices of our Unifocus Clients or other third parties, which may differ from those explained in this Notice. Individuals whose Personal Information has been submitted to us in our role as a data processor by or on behalf of a Unifocus Client and who wish to exercise any rights they may have under applicable data protection laws will be directed to the Unifocus Client.

11. Other Choices

Cookies/Automatic Tracking Technologies. As noted above, our Website may use cookies and other automatic data collection technologies. You may block or delete these technologies from your device. However, by disabling such technologies, you may not have access to the entire set of features of our Website. For more information about cookies, including links to web browser instructions for disabling and managing such technologies, visit https://optout.networkadvertising.org.

[Residents of certain states with a privacy law in effect may also have the right to opt out of sales and sharing/targeted advertising via cookies by using an opt-out preference signal. The Global Privacy Control signal is currently the only opt-out preference signal we can recognize. You can visit https://globalprivacycontrol.org to learn how to configure your device to send such signals. We will honor and process opt-out preference signals in accordance with applicable law. Please note that your opt-out choice will only apply to your use of our Website through the current browser or device you are using and only so long as that browser’s cookies are not erased. You will need to configure each device and browser you use to visit our Website to send such signals to completely opt out using this method. Please note that you may still receive generalized ads after opting out and an opt-out preference signal will not impact essential cookies used on the Website. ]

Promotional Emails. You may opt out of receiving promotional emails from us by following the instructions in those emails or by logging into your account and managing your contact preferences. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Marketing Phone Calls. With your consent, we may engage in marketing and other automated communications, which may include phone calls made using an automatic telephone dialing system or artificial prerecorded voice. You are not required to consent to such communications as a condition of purchasing products or services, and you may revoke consent at any time by contacting us via the methods described in Section 10 “How to Contact Us.”

Text Messages. With your consent, we may send marketing and/or non-marketing communications by text message (e.g. SMS and MMS). You are not required to consent to such communications as a condition of purchasing products or services, and you may revoke your consent at any time by replying “STOP” (or similar revocation language as permitted under applicable law) to the text message you receive from us or by contacting us via the methods described in Section 10 “How to Contact Us.” Please note that you may be subscribed across different short codes used by Unifocus, and therefore you must separately submit an opt-out request to each short code from which you wish to unsubscribe. After revoking consent, you may receive a confirmation text that you have been opted out. For additional information, please review Section 9 “Electronic Communications” of the Unifocus Website Terms of Use.

Please note, we will not share your text messaging opt-in data and consent with any third parties for their marketing purposes. However, as indicated in Section 4 “With Whom We Disclose Your Information,” we may disclose this information to third parties that support our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

Push Notifications to Mobile Devices. With your consent, we may send promotional and other push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

12. Additional Information for Residents Of California

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (Civil Code Section 1798.100, et seq.) (“California Law”), provides eligible California residents with specific rights with respect to our collection, retention, disclosure, selling, sharing, and use of Personal Information. This section on Additional Information for Residents of California supplements this Notice and applies solely to eligible residents of the State of California. Any terms used but not defined in this section have the same meaning as defined in California Law.

Collection of Personal Information

In the preceding twelve (12) months, we have collected categories of Personal Information as discussed in Section 1 “Your Information We Collect” from the sources of Personal Information as discussed in Section 2 “How We Collect Your Information.” The business or commercial purpose for collecting that information is disclosed in Section 3 “How We Use Your Information.”

Disclosure of Personal Information

In the preceding twelve (12) months, we may have disclosed your Personal Information for a business or commercial purpose described in Section 3 “How We Use Your Information” to the categories of third parties described in Section 4 “With Whom We Disclose Your Information.”

Sales and Shares of Personal Information

We do not sell your Personal Information for monetary profit. However, we engage in certain information disclosure activities that may be considered “sales” or “sharing” under California Law. In the last twelve (12) months, we may have sold or shared the following Personal Information:


Category	Business or Commercial Purpose	Categories of Third Parties to Whom Personal Information was Disclosed That May be Considered a “Sale” / “Sharing” Under California Law
Identifiers	● To provide you with personal advertising and content	● Advertisers and advertising networks
Internet or other similar network activity.	● To provide you with personal advertising and content	● Advertisers and advertising networks

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

California Privacy Rights

California Law provides consumers with specific rights regarding their Personal Information. The following section describes your California Law rights and explains how to exercise those rights. Your California Law rights include the:

Right to Know or Access: You have the right to request that we disclose the Personal Information we collected about you, including the categories of Personal Information collected and categories of sources; the categories of Personal Information sold, shared, or disclosed for a business purpose and the categories of third parties to whom Personal Information was sold, shared, or disclosed; the business or commercial purpose for collecting, selling, or sharing Personal Information; and the specific pieces of Personal Information that we have collected about you.
Right to Delete: You have the right to request that we delete any of your Personal Information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Identity Verification”), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
Right to Correct Inaccurate Personal Information: You have the right to request that we correct any of your Personal Information we maintain about you that is inaccurate.
Right to Opt Out of Sales or Sharing of Personal Information: We do not sell your Personal Information for monetary profit. However, we may engage in certain information disclosure activities that may be considered “sales” or “sharing” under California Law. If we sell your Personal Information to or share such information with third parties, you have the right to opt out of the sale or sharing of such information. To exercise the right to opt out, you (or your authorized representative) may submit a request to us by visiting the Your Privacy Choices link in the footer of our Website.
Right to Limit the Use and Disclosure of Sensitive Personal Information: You have the right to limit how we use and disclose your Sensitive Personal Information. To exercise the right to limit, you (or your authorized representative) may submit a request to us by visiting the Your Privacy Choices link in the footer of our Website.
Right to Non-Discrimination: We will not discriminate against you for choosing to exercise any of your rights. If you exercise certain rights, understand that you may be unable to use or access certain features of the Services.

If you have an opt-out preference signal enabled, you will automatically be opted out of the sale or sharing of your information, but we may ask you to confirm your preference if you have previously consented to the sale or sharing of your Personal Information. For additional information regarding how an opt-out preference signal will be processed and how you can use an opt-out preference signal, please see Section 11 “Other Choices.”

If a transaction requires the use or disclosure of your Sensitive Personal Information in order to complete the transaction, we will notify you and provide instructions on how you can reauthorize such use or disclosure.

Exercising Your Rights

To exercise your California Law privacy rights, please submit a request by using the interactive form described in this section, available at [INSERT LINK HERE] or contacting us via the methods described in Section 10 “How to Contact Us.”

In addition, to the extent you have provided consent for our collection and/or processing of your Personal Information and wish to revoke that consent, please contact us via the methods described in Section 10 “How to Contact Us.”

Identity Verification

We may require you to prove your identity to exercise certain rights. Depending on your request, we may ask for information such as your name, telephone number, email address, and/or date of last communication with us. We may also ask you to provide a signed declaration confirming your identity. We will only use Personal Information provided in your consumer request to verify your identity or authority to make the request.

Only you, your parent, guardian (if you are under 13 years of age), conservator, a person to whom you have given power of attorney, or an authorized agent may make a verifiable consumer request related to your Personal Information. You may, however, make a verifiable consumer request on behalf of your minor child if necessary. Your verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative. We cannot respond to certain requests if we cannot verify your identity or authority to make the request. You may only make a verifiable consumer request for your right to access twice within a 12-month period.

Data Retention

Notice of Financial Incentive

We may offer you various incentives, including special offers, discounts, rewards, and coupons pursuant to certain rewards and loyalty programs (each, a “Rewards Program”), throughout the year for providing us with your Personal Information. Categories of Personal Information that may be collected pursuant to a Rewards Program, include, but are not limited to, the categories of Personal Information described in Section 1 “Your Information We Collect.”

We do not assign a monetary value to the data we collect, but based on a good-faith estimate, we believe the value received from your Personal Information is reasonably equal to the value of the benefit we offer you pursuant to a Rewards Program. This estimate is not specific to any specific individual who participates in a Rewards Program (a “Member”) and may vary by Member. We have calculated such value by taking into consideration, without limitation, relevant factors related to the estimated value of such information to us, as set forth under California Law.

If eligible, you may opt into a Rewards Program by following the instructions set forth in a Rewards Program’s terms and conditions and, if applicable, by creating a member account on the Rewards Program’s website. Material terms of participating in a Rewards Program, including all terms and conditions concerning the collection, use, and retention of a Member’s Personal Information, are set forth in the applicable terms and conditions, this Notice, and/or our Terms of Use and should be carefully reviewed prior to participation in a Rewards Program.

You have the right to cancel your membership and participation in a Rewards Program at any time. To opt out of a Rewards Program, including the receipt of marketing emails provided pursuant to your status as a Member of a Rewards Program, please contact us via the methods described in Section 10 “How to Contact Us.”

Your Rights Under “Shine the Light”

In addition to your rights under California Law, California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure, if any, of their Personal Information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of Personal Information disclosed and the names and addresses of all third parties that received Personal Information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2026 will receive information about 2025 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing by contacting us via the methods described in Section 10 “How to Contact Us.”

13. Additional Information for Residents of Other States

Eligible residents of states in which there is a comprehensive privacy law in effect, including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, also have rights with respect to the Personal Information, also known as personal data, that we collect about you. This section supplements this Notice and applies solely to eligible residents of U.S. states with applicable comprehensive privacy laws in effect. Any terms not defined in this section have the same meaning as defined under applicable law. Subject to certain exceptions, if you are an eligible resident of one of these states, you have certain privacy rights which may include, depending on your state of residency:

Right to Know/Access: You have the right to confirm whether we process your Personal Information and access such Personal Information. You also have the right to obtain your Personal Information in a portable, and to the extent reasonably feasible, readily usable format that you can transmit without hindrance. In addition, Delaware and Maryland residents have the right to obtain a list of the categories of third parties to which we have disclosed their Personal Information, and Connecticut, Minnesota, and Oregon residents have the right to receive a list of specific third parties to which we have disclosed any Personal Information.
Right to Delete: You have the right to request that we delete the Personal Information you have provided to us or that we have otherwise obtained about you.
Right to Correct: You have the right to request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information.
Right to Opt Out: You have the right to opt out of the processing of your Personal Information for the purposes of (i) targeted advertising, (ii) the sale of your Personal Information, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.
Please note that we do not engage in such profiling as defined under applicable law, but we may sell [1] or use your Personal Information as described in Section 3 “How We Use Your Information” for targeted advertising purposes. If you have an opt-out preference signal enabled, you will automatically be opted out of the sale or use of your information for targeted advertising, but we may ask you to confirm your preference if you have previously consented to such processing activities. For additional information regarding how an opt-out preference signal will be processed and how you can use an opt-out preference signal, please see Section 11 “Other Choices.”
Right to Appeal: You have the right to appeal our decision with regard to your request to exercise any rights described herein.

NOTICE TO TEXAS CONSUMERS: We may sell your sensitive personal data.

The exact scope of these rights may vary by state. You do not need to create an account with us to exercise your state privacy law rights. To exercise the rights described in this section, including your opt-out rights, please submit a consumer request to us by using the interactive form available at [INSERT LINK HERE] or contacting us via the methods described in Section 10 “How to Contact Us.”

Rhode Island has a unique disclosure requirement. Specifically, “[i]f a commercial website or internet service provider collects, stores, and sells customers’ personally identifiable information, then the controller shall, in its customer agreement or incorporated addendum, or in another conspicuous location on its website or online service platform where similar notices are customarily posted: … (2) Identify all third parties to whom the controller has sold or may sell customers' personally identifiable information.”

14. Canadian Privacy Rights

If you are located in Canada, the Personal Information Protection and Electronic Documents Act and applicable provincial privacy legislation (collectively, “Canadian Privacy Laws”) govern the collection, use, and disclosure of Personal Information by organizations in the course of commercial activities. If you are located in Canada, this Canadian Privacy Rights section applies to you. Additionally, in certain Canadian provinces, provincial privacy legislation will apply to you, namely, for the Province of Alberta – the Personal Information Protection Act (Alberta), for the Province of British Columbia – the Personal Information Protection Act (British Columbia), and for the Province of Quebec – the Act respecting the protection of Personal Information in the private sector also applies to you and the expression “Canadian Privacy Laws” therefore also includes reference to these provincial laws. If you live in Canada and any part of our general Notice conflicts with this Canadian Privacy Rights section, this Canadian Privacy Rights section governs to the extent of the conflict.

Personal Information

Under Canadian Privacy Laws, “personal information” means any information about an identifiable individual, which may, in certain circumstances, include information gathered from your use of the Services.

Consent

In Canada, express or implied consent is the legal basis upon which organizations may collect, use, and disclose Personal Information. Accordingly, Personal Information will only be collected, used, and disclosed by us for the purposes described above in Section 3 “How We Use Your Personal Information,” with your express or implied consent. We will collect your express consent for any sensitive Personal Information that we may collect, use, or disclose. Otherwise, your continued use of the Services signifies your consent to our collection, use, and disclosure of your Personal Information as described in this Notice, as it may be amended from time to time after you have been informed of any such amendment. Your continued use of the Services after having been informed of any amendment to this Notice will be deemed a consent by you to any such amendment; if you do not agree with this Notice or any amendment, do not access the Services. If you provide Personal Information of a third party to us, you represent that you have complied with the requirements of Canadian Privacy Laws with regards to its collection before providing it to us and for our use and disclosure as set out in this Notice.

Online Behavioral Advertising

With respect to the information that we collect using cookies or similar technologies that we have described above, you can opt out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and an opt-out tool created by the Network Advertising Initiative. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Right to be Informed

You have the right to be informed about the Personal Information that we collect, use, process, disclose, retain, and have deleted about you. You may request additional information to clarify the extent of your consent.

Right to an Accounting

You have the right to receive an accounting of the categories of third parties to whom we have disclosed your Personal Information.

Rights of Access, Correction

You have the right to access the Personal Information we maintain about you and you have the right to correct or supplement your Personal Information if it is inaccurate or misleading and to have it completed if it is incomplete. Where appropriate, you have the right to have Personal Information that you have corrected or supplemented transmitted to third parties who have had access to your Personal Information.

Right to be Notified of a Data Breach

If you are in Quebec, you have the right to be informed of a confidentiality breach involving your Personal Information that may cause you a serious harm. If you are in the rest of Canada, you have the right to be informed of a breach of security safeguards affecting your Personal Information where there is a real risk of significant harm to you.

Right to Lodge Complaints

You have the right to lodge a complaint about our collection, use, or disclosure of your Personal Information with the Office of the Privacy Commissioner of Canada and any applicable provincial privacy commissioner’s office having jurisdiction.

Additional Rights in Quebec

If you are in the province of Quebec, you have the following additional rights:

Right of Deletion: You may request under certain circumstances the deletion of your Personal Information.
Right to Data Portability: As of September 22, 2024, you will have the right to be provided, in a structured, commonly used and machine-readable format, with a copy of your Personal Information or to have it transferred directly to another entity or person.

To exercise the above rights, please get in touch with us using the contact information provided in Section 10 “How to Contact Us.” We will consider and process your request within a reasonable period of time and in any event within thirty (30) days of receipt of your request or such longer time as we may be permitted under Canadian Privacy Laws. Please be aware that under certain circumstances, Canadian Privacy Laws may limit your exercise of these rights.

If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If we refuse to rectify your Personal Information, we will attach a statement to the record that sets out the reason why we have refused to make the rectification.

We will also retain the Personal Information that has been the subject of an access request or a rectification request for as long as necessary to allow you to exhaust any recourse provided by law.

International Transfers

Your Personal Information may be transferred to and stored at a location outside of your jurisdiction of residence. Please note that local data protection laws where your Personal Information is stored or processed may not provide as much protection as the data protection laws in force in your jurisdiction of residence, but we nevertheless will take reasonable steps designed to ensure that your Personal Information will not be used by such persons storing or processing the information for any purpose other than assisting us for the purposes described in this Notice. If you would like to receive more information about our policies and practices with respect to our use of service providers outside of Canada who handle your Personal Information or if you have any questions about our collection, use, disclosure, or storage by any service providers outside of Canada on our behalf, please contact us at the address provided in Section 10 “How to Contact Us.”

If you provide Personal Information of a third party to us, you represent that you have complied with all the obligations imposed by Canadian Privacy Laws regarding the transfer of Personal Information outside the jurisdiction of residence.

Business Transfers

Where we disclose your Personal Information in the event of a business transfer described in our Notice above, we will require that the information is treated confidentially by the parties to the transaction and that the information will be protected by security safeguards appropriate to its sensitivity. If the transfer is completed we will also require that the parties to the transaction continue to treat your Personal Information in accordance with Canadian Privacy Laws.

Service Providers

Where we disclose Personal Information to service providers, we ensure that they are bound by contractual obligations to:

Use Personal Information only for providing the service(s);
Refrain from disclosing or communicating Personal Information without our consent;
Implement rigorous security measures;
Allow us to audit these measures;
Notify us immediately of a confidentiality breach; and
Destroy Personal Information at the end of the contract.
a framework applicable to the use, communication, retention, and destruction of Personal Information;
the roles and responsibilities of our employees throughout the lifecycle of the Personal Information; and
a process for handling complaints concerning the protection of Personal Information.

Electronic Marketing Messages

We send electronic marketing messages for the purposes described above in this Policy; however, notwithstanding our opt-in/opt-out practices described above, Canada’s anti-spam legislation contains special rules that regulate the way in which we may send these electronic messages to you. If you are located in Canada we will only send electronic marketing messages to you if we have your prior opt-in consent, unless an exception or a specific form of implied consent applies.

Information Security and Governance

Our internal policies and practices provide for:

Each employee who uses Personal Information is bound by confidentiality obligations and has received appropriate training. In addition, each employee may only access Personal Information that is necessary for the performance of his or her duties. In the event of a breach, our governance policies and practices provide for sanctions.

15. Additional Information for Residents of the European Economic Area (EEA) and the United Kingdom (UK)

The General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and the UK GDPR (as defined in the Data Protection Act 2018) provide eligible residents of the EEA and the UK with specific rights regarding their Personal Information. This section supplements this Notice and applies solely to eligible residents of the EEA and the UK. Any terms used but not defined in this section have the same meaning as defined in the GDPR.

Legal Basis for Processing Personal Information

We process your Personal Information on the following legal bases:

Consent: Where you have given us explicit consent to process your Personal Information for specific purposes.
Contract: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into such a contract.
Legal Obligation: Where we need to process your Personal Information to comply with a legal obligation.
Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided these interests are not overridden by your rights and interests.
Right of Access: You have the right to request access to the Personal Information we hold about you.
Right to Rectification: You have the right to request that we correct any inaccuracies in the Personal Information we hold about you.
Right to Erasure: You have the right to request that we delete your Personal Information in certain circumstances.
Right to Restriction of Processing: You have the right to request that we restrict the processing of your Personal Information in certain circumstances.
Right to Data Portability: You have the right to receive your Personal Information in a structured, commonly used, and machine-readable format and to have that information transmitted to another controller, where technically feasible.
Right to Object: You have the right to object to the processing of your Personal Information based on our legitimate interests. You also have the right to object to the processing of your Personal Information for direct marketing purposes.
Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your Personal Information violates the GDPR.

Your GDPR Rights

The GDPR provides you with the following rights:

Exercising Your GDPR Rights

To exercise your GDPR rights, please submit a request by contacting us via the methods described in Section 10 “How to Contact Us.” We may require you to prove your identity to ensure that your Personal Information is not disclosed to unauthorized individuals. Depending on your request, we may ask for information such as your name, email address, and/or date of last communication with us. We will only use Personal Information provided in your request to verify your identity and to process your request.

International Data Transfers

Your Personal Information may be transferred to and processed in countries outside of the EEA and the UK, including the United States. We will take appropriate measures designed to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it, in accordance with applicable data protection laws.

Data Retention

We retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected or otherwise processed, including for the purposes of satisfying any legal, accounting, or reporting requirements. When determining the retention period, we consider the nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your Personal Information, and applicable legal requirements.

By including this section, we aim to provide greater transparency about our data processing practices and to comply with our obligations under the GDPR.

If you have any questions or concerns about this section or our privacy practices, please contact us using the methods described in Section 10 “How to Contact Us.”