Commer Group Technology Services Privacy Policy

Effective Date: June 2, 2025

At Commer Group Technology Services, we are committed to protecting the privacy of your personal information. This Privacy Policy outlines how we collect, use, disclose, and protect the personal information you provide to us, in accordance with applicable privacy legislation in Ontario and Canada, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the Personal Health Information Protection Act (PHIPA) or other sector-specific legislation.

1. What is Personal Information?

Personal information is information about an identifiable individual. It does not include information that is aggregated and cannot be associated with an identifiable individual, or information that is publicly available (e.g., names, addresses, and telephone numbers found in public telephone directories). Examples of personal information we may collect include, but are not limited to:

• Name
• Contact information (e.g., address, email address, phone number)
• Date of birth
• Payment information (e.g., credit card details)

2. How We Collect Your Personal Information

We collect personal information through various means, including:

• Directly from you: When you interact with us, such as when you fill out a form, sign up for a service, contact customer service.
• Automatically: When you visit our website or use our services, we may collect certain information automatically through technologies such as cookies, web beacons, and similar tracking technologies. This may include your IP address, browser type, operating system, referring URLs, and website activity.
• From third parties: In some cases, we may receive personal information from third parties with your consent or as permitted by law (e.g., business partners, service providers).

3. How We Use Your Personal Information

We use your personal information for the following purposes:

• To provide you with the products, services, or information you request.
• To process your transactions and manage your accounts.
• To communicate with you about our products, services, offers, and promotions.
• To improve our products, services, and website.
• To personalize your experience with us.
• To conduct research and analysis.
• To comply with legal and regulatory requirements.
• To protect our rights and property and the safety of our users.

4. When We Disclose Your Personal Information

We may disclose your personal information to third parties in the following circumstances:

• With your consent: We will obtain your consent before disclosing your personal information to third parties for purposes other than those for which it was originally collected.
• Service Providers: We may share your personal information with third-party service providers who perform services on our behalf (e.g., payment processing, data hosting, marketing, analytics). These service providers are contractually obligated to protect your information and are prohibited from using it for any other purpose.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity.
• Legal Requirements: We may disclose your personal information if required to do so by law, court order, or governmental regulation, or if we believe in good faith that such disclosure is necessary to protect our rights, property, or the safety of others.

5. Consent

We collect, use, and disclose your personal information with your consent, except where otherwise permitted or required by law. Your consent may be express (e.g., by signing a form or checking a box) or implied (e.g., by continuing to use our services after being notified of this policy). You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Please note that withdrawing consent may limit our ability to provide you with certain products or services.

6. How We Protect Your Personal Information

We employ a variety of security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Technological safeguards: [e.g., encryption, firewalls, secure servers, access controls, regular security updates]
• Organizational safeguards: [e.g., employee training, clear privacy policies and procedures, data minimization]

While we strive to protect your personal information, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

7. Retention of Your Personal Information

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. When your personal information is no longer required, we will securely dispose of it in a manner that prevents unauthorized access.

8. Accessing and Correcting Your Personal Information

You have the right to access and correct your personal information held by us, subject to certain exceptions prescribed by law. To request access to or correction of your personal information, please contact us using the information provided below. We may require you to verify your identity before processing your request.

9. Links to Third-Party Websites

Our website or services may contain links to third-party websites that are not operated by us. This Privacy Policy does not apply to the practices of these third parties. We encourage you to review the privacy policies of any third-party websites you visit.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated Privacy Policy on our website and update the “Effective Date” at the top of this policy. Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of the updated terms.