Privacy Policy

Effective date: August 30, 2026
Last updated: August 30, 2026

1. Who We Are

16032460 Canada Inc. (“Company,” “we,” “us,” or “our”) provides reputation management, online monitoring, content review, advisory, and related services throughout Canada.

This Privacy Policy explains how we collect, use, disclose, retain, safeguard, and otherwise handle personal information through our website, client portals, communications, and services.

This Policy is intended to comply with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act, SC 2000, c 5 (“PIPEDA”), and substantially similar provincial legislation, including Alberta’s Personal Information Protection Act, SA 2003, c P-6.5, British Columbia’s Personal Information Protection Act, SBC 2003, c 63, and Quebec’s Act respecting the protection of personal information in the private sector, CQLR c P-39.1.

The applicable law depends on the nature of the information, the parties involved, and the province in which the collection, use, or disclosure occurs. Organizations remain responsible for personal information transferred to service providers for processing.

2. Personal Information We Collect

“Personal information” means information about an identifiable individual, subject to applicable legal exceptions.

Depending on how you interact with us, we may collect:

name, address, telephone number, email address, and other contact information;
account credentials and authentication information;
billing, payment, and transaction information;
employer, occupation, business, and professional information;
information contained in inquiries, complaints, reviews, testimonials, correspondence, and service requests;
information about your reputation-management objectives and instructions;
publicly available information, including online reviews, social-media content, news articles, directory listings, search-engine results, and other online references;
information concerning third parties that you provide to us;
technical information, including IP address, browser type, device identifiers, operating system, approximate location, referring URL, and website activity;
cookies and similar technologies; and
information required to investigate security incidents, fraud, misuse, or suspected violations of law.

Reputation-related information may be sensitive depending on its nature and context. We will limit collection to information necessary for identified purposes and collect it by lawful and fair means.

3. How We Collect Information

We may collect personal information:

directly from you, including when you contact us, request a consultation, create an account, purchase services, submit content, or communicate with us;
from your organization, employer, authorized representative, or professional advisers;
from publicly accessible sources, such as websites, search engines, social-media platforms, review sites, news publications, and public records, where permitted by law;
from service providers, analytics providers, payment processors, advertising partners, and identity-verification providers; and
through cookies, logs, pixels, and comparable technologies.

Where required by law, we will identify the purposes for collection before or when information is collected.

4. Purposes for Collection, Use, and Disclosure

We may collect, use, and disclose personal information for the following purposes:

providing, administering, and improving our services;
monitoring online references, reviews, media, and other reputation-related content;
preparing reports, assessments, recommendations, and client deliverables;
communicating with clients, prospective clients, and authorized representatives;
verifying identity, authority, and account information;
processing payments and maintaining business records;
responding to inquiries, complaints, and access or correction requests;
managing contracts and business relationships;
maintaining website, account, and information-security functionality;
detecting, preventing, and investigating fraud, abuse, unauthorized activity, and legal violations;
complying with court orders, legal requirements, regulatory requests, and professional obligations;
conducting analytics, quality assurance, research, and service development, using de-identified or aggregated information where reasonably practicable; and
sending marketing communications where permitted by law and consistent with your preferences.

We will not use personal information for a new purpose without identifying that purpose and obtaining consent where required. Under PIPEDA, collection, use, and disclosure must be for purposes a reasonable person would consider appropriate in the circumstances.

5. Consent

We generally obtain knowledge and consent before collecting, using, or disclosing personal information. Consent may be express or implied where permitted by applicable law and the circumstances.

Consent must be meaningful. We will provide information sufficient for a reasonable person to understand the nature, purposes, and consequences of the relevant collection, use, or disclosure.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal may prevent us from providing certain services or maintaining an account. We will explain the reasonably foreseeable consequences of withdrawal.

Quebec

Where Quebec law applies, consent must generally be clear, free, informed, and given for specific purposes in clear and simple language. Consent must be requested separately from other information where required. Consent concerning sensitive personal information must be express where required by law.

We will not make the supply of a product or service conditional on consent to collection, use, or disclosure beyond what is necessary for the product or service, except as permitted by applicable law.

6. Publicly Available and Reputation-Related Information

Our services may require us to review information that is publicly accessible online. We will:

collect only information reasonably necessary for the agreed service purposes;
use the information only for identified and legitimate purposes;
respect applicable website terms, access restrictions, and legal requirements;
avoid unnecessary collection of unrelated personal information;
use reasonable measures to reduce the risk of re-identification when information is de-identified; and
provide reasonable assistance concerning information we hold about you, subject to applicable exceptions.

Public availability does not make information unrestricted for all purposes. We will assess the appropriateness of collection and use in context.

7. Disclosure to Service Providers and Other Parties

We may disclose personal information to:

hosting, cloud-storage, cybersecurity, information-technology, and communications providers;
payment processors, accounting providers, and professional advisers;
analytics, customer-support, and relationship-management providers;
contractors and consultants assisting with the services;
legal, regulatory, governmental, or law-enforcement authorities where required or permitted by law;
parties involved in a financing, reorganization, merger, acquisition, or sale of all or part of our business; and
persons whom you authorize us to contact or to whom you direct us to disclose information.

Service providers may process information only for authorized purposes and must provide safeguards appropriate to the information and services involved.

We remain responsible for information in our possession or control, including information transferred to a third party for processing.

We do not sell personal information for monetary consideration.

8. Processing Outside Quebec and Canada

Personal information may be stored or processed in Canada, the United States, or another jurisdiction where we or our service providers operate.

Before communicating personal information outside Quebec, where Quebec law applies, we will conduct the required privacy impact assessment and assess the sensitivity of the information, the purposes of use, applicable contractual safeguards, and the legal framework of the receiving jurisdiction.

We will communicate the information only where the assessment establishes adequate protection and will use a written agreement where required.

Information processed outside Canada may be accessible to courts, law-enforcement agencies, and national-security authorities in the relevant jurisdiction.

9. Cookies and Similar Technologies

We may use cookies, pixels, tags, logs, and similar technologies to:

operate and secure the website;
remember preferences;
understand website use and performance;
measure marketing effectiveness; and
personalize content or communications where permitted.

You may adjust browser settings to reject or delete cookies. Certain website functions may not operate properly if cookies are disabled.

Where required, we will obtain consent for non-essential cookies and provide information about the relevant purposes and means of collection. Quebec residents will receive the disclosures required for technologies that identify, locate, or profile an individual.

10. Marketing Communications

We may send service-related communications without separate marketing consent where permitted by law.

We will send commercial electronic messages only in accordance with applicable requirements, including the Electronic Commerce Protection Act, SC 2010, c 23, where applicable. Marketing messages will identify us and include an unsubscribe mechanism.

You may opt out of marketing communications at any time by using the unsubscribe link or contacting us. We will continue to send communications reasonably necessary to administer your account, provide services, or address legal or security matters.

11. Automated Processing

We do not make decisions about individuals based exclusively on automated processing unless disclosed and permitted by applicable law.

If we use personal information to render a decision based exclusively on automated processing where Quebec law applies, we will provide the notices and procedural rights required by that law, including the opportunity to submit observations to a member of our personnel who can review the decision.

12. Safeguards

We use physical, organizational, and technological safeguards appropriate to the sensitivity of personal information, including as appropriate:

access controls and authentication;
confidentiality obligations;
employee training;
contractual controls for service providers;
secure transmission and storage;
monitoring and logging;
backup and recovery procedures; and
secure destruction or anonymization practices.

No method of transmission or storage is completely secure. We cannot guarantee absolute security.

13. Retention and Destruction

We retain personal information only as long as reasonably necessary to fulfil identified purposes, provide services, satisfy legal, accounting, insurance, dispute-resolution, and professional requirements, and protect our legitimate interests.

When information is no longer required, we will securely destroy it or anonymize it where appropriate. Under Quebec law, information must generally be destroyed or anonymized when the purposes for which it was collected or used have been achieved, subject to statutory preservation periods.

Retention periods may vary according to:

the nature and sensitivity of the information;
the purpose for which it was collected;
whether it was used to make a decision;
contractual and legal requirements; and
the existence of a complaint, investigation, audit, or dispute.

14. Data Breaches

If a breach of security safeguards occurs, we will assess the incident and take steps required by applicable law, including containment, investigation, remediation, documentation, and notification.

Under PIPEDA, notification obligations may arise where a breach creates a real risk of significant harm, assessed by considering factors including the sensitivity of the information and the probability of misuse.

Where required, we will notify affected individuals and the applicable privacy regulator as soon as feasible and provide information necessary to understand and mitigate the risk.

15. Access, Correction, and Other Rights

Subject to legal exceptions, you may request:

confirmation of whether we hold personal information about you;
access to that information and an account of its use and disclosure;
correction of inaccurate, incomplete, or outdated information;
information about the source of information, where available;
information about our privacy practices and service providers;
withdrawal of consent;
deletion, cessation of dissemination, or de-indexing where available under applicable law; and
portability of certain computerized information where required by law.

Requests must be made in writing and may require reasonable identity verification. We will respond within the time required by applicable law. Under PIPEDA, an organization generally must respond within 30 days, subject to permitted extensions.

To make a request, contact our Privacy Officer using the information below.

16. Complaints

Questions or complaints should first be directed to our Privacy Officer. We will investigate complaints and respond within a reasonable period.

If you are not satisfied with our response, you may contact the privacy regulator with jurisdiction over the matter, including:

the Office of the Privacy Commissioner of Canada;
the Office of the Information and Privacy Commissioner of Alberta;
the Office of the Information and Privacy Commissioner for British Columbia; or
the Commission d’accès à l’information du Québec.

Applicable legislation recognizes an individual’s ability to challenge an organization’s compliance with privacy principles.

17. Children

Our website and services are not directed to children under 14. We do not knowingly collect personal information from a child under 14 without legally required consent. Where Quebec law applies, collection from a child under 14 generally requires consent from the person having parental authority or tutor unless collection is clearly for the child’s benefit.

18. Third-Party Websites

Our website may link to third-party websites, platforms, review sites, or social-media services. Their privacy practices are governed by their own policies. We are not responsible for their content, security, or privacy practices.

19. Changes to This Policy

We may amend this Policy from time to time. The updated version will be posted on our website with a revised effective date. Where required, we will provide additional notice or obtain consent for material changes to purposes, uses, or disclosures.

20. Contact Information

Privacy Officer: Michael Davey
Company: 16032460 Canada Inc.
Address: 34 Minowan Miikan Lane, Toronto, Ontario, Canada, M6J 0G3
Email: info@needpivot.com
Telephone: (437) 317-0105