BlueCat privacy policy

This policy explains how and why we, BlueCat Networks, Inc. and our affiliates (“BlueCat”, “we”), collect, use, hold, and disclose your personal data when you visit bluecatnetworks.com and related websites (our “Websites”), use our products and services (our “Solutions”), or otherwise provide personal data to us.

By accessing our Websites and using our Solutions, you consent to us collecting, holding, using, and disclosing your personal data in accordance with this policy. For further information regarding how we handle personal data in connection with our Solutions, please also refer to our Data Processing Agreement.

This policy does not apply to any information collected by any third party.

I.    What is personal data?

Personal data (or personal information) means any information relating to an identified or identifiable natural person or household.

II.    What personal data do we collect and hold?

We may collect your personal data in different ways depending on the business context and the purpose for which it is collected.

A.    When using our solutions

In using our Solutions, we may collect the information below, including through automated data collection technologies:

1. Billing and contact information, such as your name, email address, phone number, job title, location, or other similar information.
2. Login information, such as your username and password.
3. DNS and DHCP logs for users of our Solutions, which may include endpoint Internet Protocol (IP) addresses, DNS queries and usernames, or MAC addresses and host IDs, where the associated features are enabled.
4. Information you provide to us during our delivery of professional or support services, such as IP addresses, MAC addresses, host names, contact information, and other information you share with us.
5. Information regarding your usage of our Solutions, such as location data, logs, information about your devices or internet connection, or similar data regarding your use.

B.    When accessing our websites

By accessing our Websites, we may also collect the information below, including through automated data collection technologies:

1. Information you provide to us when you submit forms, such as requests for being contacted, requests for access to documents or tools, application forms, feedback, or registration for events.
2. Content that you submit in our online forums, such as our Care Community or Network VIP, or through surveys or questionnaires.
3. Information you provide when you interact with any of our chatbots.
4. Information about how you access, use, and interact with our Websites.
5. Any other information you voluntarily provide to us.
   1. If you visit our offices or if you attend an event sponsored or attended by BlueCat, we may collect personal data such as your name, address, phone number, email address, title, organization, or other similar information.
   2. If you apply for a position at BlueCat we will collect personal data to allow us to consider your application or to process your hiring. We and our service providers may also collect voluntary demographic data to obtain general insights about our applicants and to evaluate our diversity and inclusion efforts. You may elect to not provide voluntary demographic data and it will not affect your job application in any way. Demographic data will be kept separate from your name and job application.

III.    Use of cookies and similar tracking technology

Our use of pixels, cookies, and other similar tracking technologies to process personal data is explained in our Cookie notice.

IV.    Why do we collect, hold, and use your personal data?

We collect, hold, and use your personal data so that we can:

1. Provide customers or channel partners with our Solutions, including processing orders, delivering products, sending communication about our Solutions, and providing maintenance, support, and professional services.
2. Manage our relationship with our customers or channel partners, including billing, account, and subscription management.
3. Improve our Solutions and develop new products and services.
4. Improve our marketing using data analytics.
5. Secure our Solutions and detect activities that may be unlawful or violate our policies.
6. Comply with our legal obligations and assist government or law enforcement agencies or regulators when requested.
7. Provide you with news, surveys, information about other products or services that we think may be of interest to you, invitations to events, and other similar materials. You may opt out of such marketing communication in the email you receive or by contacting us at any time.
8. Facilitate conferences, webinars, and other events.
9. Provide, operate, maintain, personalize, and promote our Websites and allow you to access and use our Websites.
10. Consider applications for positions with BlueCat, derive general insights about our applicants, and complete the hiring process.
11. Undertake other activities that you may consent to from time to time.

BlueCat does not sell your personal data for monetary consideration. However, like many companies, we use services that help deliver interest-based ads to you and may transfer your personal information to business partners to deliver such ads, as described further in our Cookie notice. You can request to opt out of such transferring of your personal information by disabling “Marketing cookies” in your cookie preferences.

If you do not provide us with your personal data, we may not be able to provide you with our Solutions, communicate with you, or respond to your enquiries.

V.    How do we store and hold personal data?

We store most information about you in computer systems and databases operated either by us or our external service providers. Some information about you is recorded in paper files that we store securely.

We implement and maintain processes and security measures designed to protect personal data that we hold from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure. These processes and measures include (but are not limited to):

1. Identity and access management technologies to control access to systems on which information is processed and stored.
2. Physical safeguards such as controlled access to our facilities and secure destruction of media that holds personal data.
3. Technological safeguards, such as identity and access management technology to control access to our systems, third-party penetration testing, and use of firewalls and multi-factor authentication tools.
4. Requiring all employees to comply with internal information security policies and keep information secure.
5. Requiring all employees to complete training about information security and handling of personal data.
6. Monitoring and regularly reviewing our practices against our own policies and against industry practices.

We will also take reasonable steps to destroy or de-identify personal data once we no longer require it for the purposes for which it was collected.

VI.    Whom do we disclose your personal data to and why?

We may transfer or disclose your personal data to our affiliates and investors. We may also transfer and disclose your personal data to other third parties as follows:

1. To our authorized channel partners for them to sell you our Solutions or their related services, or to contact you regarding our Solutions or their related services.
2. To our service providers that we engage with to conduct our business. These service providers may assist us in business functions that include delivery and improvement of our Solutions, managing our relationship with you, auditing and accounting, professional services, security, marketing assistance, information technology consulting, collections, and hiring. If you use any chatbots on our Websites, your communication may also be shared with the third-party providers of the functionality of those chatbots. We enter into contracts with all our service providers that require them to comply with applicable privacy laws and to use the information we share with them only for specific permitted purposes.
3. To our marketing and advertising partners that may assist us with our marketing efforts, including online advertising. Our marketing and advertising partners may collect or receive your personal data, including by using cookies and similar technologies, to gain insights that may help us market and advertise our services to you.
4. To law enforcement agencies, courts, and regulatory authorities to respond to requests, enforce our rights, or defend ourselves against legal claims.
5. In aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you.
6. If we otherwise notify you and you consent to the sharing.

We may also share your personal data in connection with any merger, sale, change in control, or reorganization of our business.

VII.    International data transfers

As a global organization, we may transfer and access your personal data around the world for the purposes described in this policy. BlueCat primarily stores your information in Canada, the United States, and the European Economic Area. We may also disclose your personal data to recipients who are located outside the country where the personal data was collected. If we do so, we will ensure we have in place the transfer mechanics required by any applicable privacy laws. We will ensure that a transfer only takes place if an appropriate level of protection exists with the recipient and suitable safeguards are provided, including safeguards as provided for in standard contractual clauses, adequacy decisions, the EU-US Data Privacy Framework, and consent in individual cases.

VIII.    Access to and correction of your personal data

You may access or request correction to the personal data that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal data.

There is no charge for requesting access to your personal data, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on assembling large amounts of material).

We will respond to your requests to access or correct personal data in a reasonable time and will take all reasonable steps to ensure that the personal data we hold about you remains accurate, up to date, complete, relevant, and not misleading.

IX.    Retention and disposal

We will retain your personal data as needed to fulfill the purposes for which it was collected. We will also retain and use it as needed to comply with our business requirements and legal obligations, resolve disputes, and enforce our rights. Thereafter, the data will either be deleted or anonymized.

X.    Your rights regarding your personal data

Local privacy laws may give you certain rights regarding your personal data. These may include the right to:

1. Access your data.
2. Request further information about the personal data we have collected about you.
3. Have your data deleted or corrected where it is inaccurate.
4. Object to your data being processed and to restrict processing.
5. Withdraw consent to having your data processed where we process based on your consent.
6. Limit the use and disclosure of sensitive personal data.
7. Not be subject to a decision based solely on automated processing.

You may have additional or different rights under the laws that apply to our processing of your personal data. We will comply with the requirements of any law that applies to our processing of your personal data but reserve the right to limit our performance to what is legally required. Where BlueCat is acting as a data processor, we will direct you to the controller under the applicable data protection laws to action your request.

XI.    Data subject rights and complaints

We have processes in place to address any data subject rights requests. Our actions and responsibilities will depend on whether we are the controller or processor of the personal data at issue. Depending on our role as either a controller or processor, the processes for enabling data subject rights may differ and are always subject to applicable law. Please refer to the contact details section below if you would like to make a data subject rights request or need assistance with a data subject rights request. If your request relates to data for which we are a data processor, we may pass on your request to the applicable data controller.

If you have a complaint about the way in which we have handled any privacy issue, including your request for access to or correction of your personal data, you should contact us. Our contact details are set out below. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation. If you have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in your jurisdiction of residence.

XII.    Controller and processor

In countries that recognize a difference between data controllers and data processors, BlueCat generally acts as data controller for the personal data processed on our Websites, to administer our Solutions or our relationship with our customers and partners (such as billing), in connection with events we sponsor or host, or to consider job applications.

Regarding the personal data processed in our Solutions or in relation to the provision of our Solutions to you, we are generally the data processor on behalf of our customers or channel partners. For further information regarding how we handle personal data in connection with our Solutions, please also refer to our Data Processing Agreement.

XIII.    Legal basis for processing

We will only process personal data if we have a legitimate reason to do so. The legal basis for our collection and use of your personal data will depend on the circumstances in which the data is collected and will comply with the requirements of local privacy laws. The legal basis for our processing of your personal data will be one of the following:

1. You have given your consent to the processing for one or more specific purposes.
2. The processing is necessary to perform a contract with you (such as delivering our Solutions) or to take steps at your request prior to you entering into a contract.
3. The processing is necessary for us to comply with our legal obligations.
4. The processing is necessary for the pursuit of our legitimate interests.

XIV.    Notice at collection for California residents

This notice at collection is provided pursuant to the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, “CCPA”) and applies to California residents. The table below provides details regarding the types of personal information that BlueCat collects and how we use that information when an individual accesses, uses, or interacts with our Websites.

Categories of personal information about consumers we collect:* ** *No sensitive personal information about consumers is collected. **None of the information described in this notice at collection is “sold” for monetary consideration but may be “shared” as described in the section below titled “Sale or sharing of personal information” (as those terms are defined by the CCPA). You can request to opt out of such “sale” or “sharing” of your personal information by disabling “Marketing cookies” in your cookie preferences.	Identifiers and personal information such as: a unique personal identifier, online identifier, or IP address; if you fill out a “Contact Us” form or similar; a real name, alias, postal address, email address, or phone number; or your username and password if you use our Websites to log into our Solutions. Internet activity such as: a unique personal identifier; browsing history; search history; or information on a consumer’s interaction with a website, application, or advertisement, including page views and clicking tendencies. Information you provide to us when you submit forms such as: requests for being contacted; requests for access to documents or tools; application forms; feedback; or registration for events. Content that you submit in our online forums such as our Care Community or Network VIP, or through surveys or questionnaires. Information you provide when you interact with any of our chatbots. Information about how you access, use, and interact with our Websites.
The business purposes for which the above categories of personal information are collected and used:	Providing and optimizing your experience on our Websites and ensuring that our content is presented to you in the most effective manner. Communicating with you and responding to your enquiries about our Solutions, including providing you with promotional and informational communication regarding our Solutions, informing you about new Solutions, updating you about changes to our Solutions, and investigating any concerns you have about our Solutions or your interactions with us. Fulfilling transactions with you or managing our relationship with you. Engaging in analytics regarding the use of our Solutions by users to market to current or potential customers. Facilitating conferences, webinars, and other events. Developing, updating, and improving our Solutions, customer service, customer experience, and marketing efforts, and otherwise improving our knowledge and insights regarding customers. Maintaining the safety, security, and integrity of our Websites. Preventing and detecting fraud, hacking activities, security breaches, and other unlawful activities in connection with our Solutions. Considering applications for positions with BlueCat, deriving general insights about our applicants, and completing the hiring process. Complying with our legal obligations and assisting government or law enforcement agencies or regulators when requested.
The criteria used by BlueCat to determine the time period such personal information will be retained:	BlueCat will retain the personal information it collects and uses so long as it has a legitimate business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.

To learn more about our online and offline practices in connection with the collection, processing, and disclosure of personal information relating to California residents, continue to read our privacy notice for California residents below.

XV.    Privacy notice for California residents

This section is for individuals who are covered by the CCPA. It describes our online and offline practices for the collection, processing, and disclosure of personal information relating to California residents. This section is limited to our activities when we are acting as a “business” as defined by the CCPA.

For the purposes of the CCPA, “personal information” includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information” for the purposes of Section XV). We have collected the following categories of personal information within the past 12 months and shared it with the categories of third parties as indicated in the table below:

Category	Examples	Collected	Categories of third parties this personal information has been shared with
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifier	Yes	Channel partners, service providers, and marketing and advertising partners
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes	Channel partners and service providers
Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, or pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information)	No	N/A
Commercial information	Records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies	Yes	Channel partners and service providers
Biometric information	Genetic, physiological, behavioral, or biological characteristics; activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, or voiceprints; iris or retina scans; keystroke, gait, or other physical patterns; and sleep, health, or exercise data	No	N/A
Internet or other similar network activity	Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement	Yes	Channel partners, service providers, and marketing and advertising partners
Geolocation data	Physical location or movements	Yes	Service providers
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	No	N/A
Professional or employment-related information	Current or past job history or performance evaluations	Yes	Service providers
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	No	N/A
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes	No	N/A
Sensitive personal information	Personal information that reveals: A consumer’s Social Security, driver’s license, state identification card, or passport number A consumer’s account login, financial account, or debit or credit card number in combination with any required security or access code, password, or credentials allowing access to an account A consumer’s precise geolocation A consumer’s racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership The contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication A consumer’s genetic data The processing of biometric information for the purpose of uniquely identifying a consumer Personal information collected and analyzed concerning a consumer’s health Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation	BlueCat does not use or disclose “sensitive personal information” (as defined by the CCPA) for the purposes of inferring characteristics about California consumers. Accordingly, BlueCat treats any such information as “personal information” consistent with applicable provisions of the CCPA.	N/A

Occasionally, BlueCat may be required to disclose your information to governmental authorities to comply with applicable laws and regulations or in response to legal processes. Finally, we may “aggregate” or “deidentify” information from you pursuant to the CCPA, after which the information is no longer “personal information.”

We obtain the categories of personal information listed above from the following categories of sources:

1. Directly from our customers, partners, or their agents. For example, from documents that our customers provide to us related to our Solutions.
2. Indirectly from our customers, partners, or their agents. For example, through information we collect while providing our Solutions to them.
3. Directly from attendees to our offices or events sponsored or attended by BlueCat.
4. Directly and indirectly from activity on our Websites. For example, from submissions through our Websites’ forms and portals or usage details collected automatically.
5. From third parties that interact with us in connection with our Solutions, such as third-party lead generation services.
6. From applicants for positions at BlueCat.

A.    Use of personal information

We may use or disclose the personal information we collect for the following business or commercial purposes:

1. Provide customers or channel partners with our Solutions, including processing orders, delivering products, sending communication about our Solutions, and providing you with maintenance, support, and professional services.
2. Manage our relationship with our customers or channel partners, including billing, account, and subscription management.
3. Improve our Solutions and develop new products and services.
4. Improve our marketing through using data analytics.
5. Secure our Solutions and detect activities that may be unlawful or violate our policies.
6. Comply with our legal obligations and assist government or law enforcement agencies or regulators when requested.
7. Provide you with news, surveys, information about other products or services that we think may be of interest to you, invitations to events, and other similar materials. You may opt out of such marketing communication in the email you receive or by contacting us at any time.
8. Facilitate conferences, webinars, and other events.
9. Provide, operate, maintain, personalize, and promote our Websites and allow you to access and use our Websites.
10. Consider applications for any positions with BlueCat, derive general insights about our applicants, and complete the hiring process.
11. Undertake other activities that you may consent to from time to time.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

B.    Sale or sharing of personal information

BlueCat does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.

In the past 12 months, BlueCat has not “sold” any categories of personal information, as that term is defined by the CCPA, for monetary consideration. However, like many companies, we use services that help deliver interest-based ads to you and may transfer your personal information to business partners to deliver such ads, as described further in our Cookie notice. This may be considered a “sale” or “sharing” of personal information as defined by the CCPA. You can request to opt out of such “sale” or “sharing” of your personal information by disabling “Marketing cookies” in your cookie preferences.

C.    Your rights and choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

1.    Access to specific information and data portability rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting or selling that personal information.
4. The categories of third parties with whom we shared that personal information.
5. The specific pieces of personal information we collected about you (also called a data portability request).
6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
   1. sales, identifying the personal information categories that each category of recipient purchased; and
   2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

2.    Deletion request rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will, to the best of our ability, delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3.   Right to correct inaccurate information

If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

4.    Other rights

Consumers in California also have the right to opt-out of (a) the sale of personal information, or (b) the sharing of their personal information for the purposes of cross-context behavioral advertising (as defined in the CCPA). You can request to opt out of such “sale” or “sharing” of your personal information by disabling “Marketing Cookies” in your cookie preferences.

California consumers also have the right to limit the use or disclosure of sensitive personal information by our business if such information is used or disclosed for certain purposes, as required by the CCPA.

5.    Exercising access, data portability, and deletion rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using the email address or phone number provided below.

Only you, or someone that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information. Your request must include your name, email address, mailing address, phone number, the nature of your inquiry (e.g., the right(s) being exercised) and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

As indicated above, the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

6.    Response timing and format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7.    Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

XVI.    Canadian residents

If you reside in Canada, various Canadian laws, including Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), may provide you certain rights with respect to your personal information. This includes the right to request information about the collection, use, or disclosure of your personal information; to request access to your personal information; and to challenge the accuracy and completeness of your personal information and have it amended as appropriate.

If you are a Canadian resident and would like to make a request regarding your personal information, please send a request to [email protected] with the subject line “Canada resident request” or otherwise contact us using the information in the contact details section below. We will attempt to respond to your request as quickly as possible but may ask you to provide additional information to enable us to locate your personal information or determine how it has been used or disclosed. We will provide you access, as appropriate, at minimal or no cost to you.

XVII.    Contact details

If you have any questions, comments, requests, or concerns, please contact us at:

BlueCat Networks
Attention: Legal
4100 Yonge Street, Suite 300
Toronto, Ontario M2P 2B5
Canada
Email: [email protected]
Telephone: 1-877-572-1218

XVIII.    Changes to this policy

Occasionally, we may change our policy on how we handle personal data or the types of personal data that we hold. Any changes to our policy will be published on our Websites.

You may obtain a copy of our current policy from our Websites or by contacting us at the contact details above.

Last updated: July 3, 2024