Introduction

At Spin Canada Inc. ("Spin Canada," "we," "our," or "us"), privacy and security are fundamental priorities. We are committed to transparency in the collection, use, and disclosure of personal information belonging to our users, clients, and website visitors.

This Privacy Policy explains how we handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), applicable provincial privacy legislation, and the principles of the Canadian Standards Association (CSA) Model Privacy Code.

By accessing our website or engaging our services, you acknowledge that your personal information will be collected and used as described in this Policy.

Spin Canada Inc. is the organization responsible for personal information under its control and acts as the accountable party for the purposes of this Policy.

1. What Personal Information We Collect, and Why

We collect only the personal information necessary to provide our services and improve your experience with us.

Through website forms and event registrations:

• Identity and profile data: name, job title, and professional profile.
• Contact information: business email address, telephone number.
• Organizational information: company name, website, industry sector, and approximate size.
• Engagement data: content consumed on our website, such as downloaded materials or attended webinars.

Through cookies and browsing technologies:

• Browsing preferences and pages visited.
• Device and operating system information.
• Approximate geographic location (city/region level).
• Referral source and visit duration.

Through direct contact channels (email, phone, or chat):

• Billing and payment information necessary to administer contracted services.
• Communication history: records of correspondence with our commercial, technical support, or administrative teams.

Purpose of collection: Personal information is collected to respond to inquiries, deliver contracted services, send relevant technical and commercial communications, and improve our website and service offerings. We do not collect personal information for purposes other than those identified at or before the time of collection.

 

2. How We Collect Personal Information

Information you provide directly: When you fill out a contact form, register for an event, or download materials from our website, you provide us with identifying information voluntarily.

Automated collection (cookies): When you visit our website, cookies placed by analytics tools (such as Google Analytics) record technical information — including IP address, browser type, pages visited, and session duration — in anonymized or aggregated form where possible.

Communication records: Correspondence sent to Spin Canada by email or other channels is retained as part of our client relationship records.

You may manage cookie settings directly in your browser at any time. Disabling certain cookies may affect the functionality of some website features.

3. Legal Basis and Consent

We collect, use, and disclose personal information with your knowledge and consent, or as permitted or required by law.

Consent may be express (e.g., you complete and submit a form) or implied (e.g., you provide a business card at an industry event). You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide certain services.

We will not, as a condition of supplying a product or service, require you to consent to the collection, use, or disclosure of information beyond what is necessary to fulfil the explicitly specified purpose.

4. Your Rights as an Individual

Under PIPEDA and applicable Canadian law, you have the right to:

• Know whether we hold personal information about you and how it is used.
• Access your personal information and request a copy in a readable format.
• Correct inaccurate or incomplete personal information.
• Withdraw consent to the processing of your data, subject to legal limitations.
• Request deletion of your personal information where it is no longer required for the purposes for which it was collected or as otherwise permitted by law.
• Lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Privacy Officer using the information provided in Section 11.

 

5. How Long We Retain Your Data

Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected, to maintain our contractual relationship with you, or as required by applicable law.

When personal information is no longer needed, it is securely destroyed, erased, or anonymized. Certain records may be retained longer where required by law, tax obligations, or to defend legal claims.

6. How We Protect Your Information

We employ technical, organizational, and physical safeguards appropriate to the sensitivity of the personal information we hold. These include:

• Access controls limiting personal data to authorized personnel only.
• Confidentiality agreements binding all personnel with access to personal information.
• Secure storage environments using reputable and certified infrastructure providers.

No transmission over the internet or electronic storage method is completely secure. While we apply commercially reasonable measures to protect your information, we cannot guarantee absolute security. In the event of a privacy breach that poses a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA.

7. Sharing of Personal Information

We do not sell your personal information. We may share personal information with third parties only under the following circumstances:

Service providers: Third-party vendors engaged to support our operations (e.g., CRM platforms, analytics tools, cloud infrastructure) may access personal information strictly to the extent necessary to perform their contracted functions. All such vendors are bound by contractual obligations consistent with this Policy.

Legal requirements: We may disclose personal information when required by law, court order, or a request from a regulatory or government authority with jurisdiction.

Corporate transactions: In the event of a merger, acquisition, or sale of assets, personal information may be transferred as part of the transaction, subject to equivalent privacy protections.

Protection of rights: We may disclose information to protect the rights, property, or safety of Spin Canada, our clients, or others, as permitted by law.

7.1 Cross-Border Transfers

Spin Canada operates as part of a global group with affiliates and partners in Brazil, India, and the Philippines. Personal information may be transferred to and processed in jurisdictions outside Canada. When such transfers occur, we ensure that equivalent protections are in place through contractual arrangements or other legally recognized mechanisms. By using our services, you acknowledge that your information may be processed in foreign jurisdictions.

8. Cookies

Our website uses cookies to enhance your browsing experience. Cookies are small text files stored on your device that allow us to recognize your browser and remember certain preferences.

You may disable or manage cookies through your browser settings at any time:

• Google Chrome
• Mozilla Firefox
• Safari
• Microsoft Edge

Disabling cookies may limit the functionality of certain parts of our website.

9. Amendments to This Policy

We reserve the right to update this Privacy Policy to reflect changes to our practices, services, or legal requirements. Material changes will be communicated via a notice on our website. We encourage you to review this Policy periodically. Continued use of our services following notification of changes constitutes acceptance of the revised Policy.

10. Accountability

Spin Canada is accountable for personal information in its possession or custody, including information transferred to third parties for processing. We have designated a Privacy Officer responsible for compliance with this Policy and applicable Canadian privacy law.

11. Contact — Privacy Officer

To exercise your rights, ask questions about this Policy, or report a privacy concern, please contact our Privacy Officer:

Rodrigo Borges Privacy Officer, Spin Canada Inc. 📧 rodrigo@spincanada.com 🌐 spincanada.com

If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or call 1-800-282-1376.