Website Visitor Privacy Policy

Introduction

We value your privacy and are committed to protecting yourpersonal data. This privacy policy will inform you about how we look after yourpersonal data when you visit our website and tell you about your privacy rightsand how Canadian law protects you.

Important Information and Who We Are

Purpose of This Privacy Policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up for our newsletter, purchase a product or service, or take part in a competition.

Controller

Our company is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy). If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our Data Protection Officer (DPO) using the details set out below.

Contact Details

Our full details are: McCallum and Pinard Solutions Inc.

Name or title of DPO: privacy@mpsweb.net

Email address: privacy@mpsweb.net

Postal address: 1-196 Douglas Street, Greater Sudbury, Ontario, P3E 1G1 Canada

Telephone number: (705) 805-0139

You have the right to make a complaint at any time to the Office of the Privacy Commissioner of Canada (OPC) or your provincial privacy commissioner if applicable. We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us in the first instance.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

This version was last updated on [Date]. We may update this policy from time to time and will notify you of any significant changes on our website or by contacting you directly.

Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: includes first name, last name, username or similar identifier, marital status, title, date of birth, and gender.
• Contact Data: includes billing address, delivery address, email address, and telephone numbers.
• Financial Data: includes bank account and payment card details.
• Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data: includes internet protocol (IP)address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data: includes information about how you use our website, products, and services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
• Apply for our products or services;
• Create an account on our website;
• Subscribe to our service or publications;
• Request marketing to be sent to you;
• Enter a competition, promotion, or survey; or
• Give us some feedback.

Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as setout below:

Technical Data from the following parties:

analytics providers such as Google based outside Canada;

advertising networks based inside and outside Canada; and

search information providers based inside and outside Canada.

Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services based inside and outside Canada.

Identity and Contact Data from data brokers or aggregators based inside and outside Canada.

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside Canada.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

•  Where we need to perform the contract we areabout to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what maybe of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of Your Personal Data

We may have to share your personal data with the parties setout below for the purposes set out in the table in paragraph 4 above.

•  Internal Third Parties as set out in the Glossary.
•  External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as setout in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We share your personal data within our company group. This will involve transferring your data outside of Canada.

Many of our external third parties are based outside Canada so their processing of your personal data will involve a transfer of data outside of Canada.

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Canadian government. For further details, see Government of Canada: Adequacy of the protection of personal data in non-Canadian countries.
• Where we use certain service providers, we may use specific contracts approved by the Canadian government which give personal data the same protection it has in Canada. For further details, see Government of Canada: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Canada and the US. For further details, see Government of Canada: Canada-US Privacy Shield.

Whenever we transfer your personal data out of Canada, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Canada.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.