Privacy Policy

Introduction

Welcome to our Privacy Policy. This document explains how FreshSites (referred to as "we", "us", or "our") collects, uses, discloses, and protects your personal information when you use our website or services. We are committed to handling your personal data in accordance with applicable Canadian privacy laws, including the federal Personal Information Protection and Electronic Documents Act (PIPEDA), and relevant provincial laws where applicable. By using our website or providing us with personal information, you consent to the practices described in this Privacy Policy (subject to your rights to withdraw consent, as described below).

Last Updated: November 27th, 2025.

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. If we make significant changes, we will post the updated Policy with a new effective date. We encourage you to review this Policy periodically for any updates or changes, as keeping the policy up-to-date and aligned with actual data practices is considered a best practice.

Data We Collect

We only collect personal information that is necessary for the purposes identified in this Policy. The types of personal data we collect fall into two general categories:

• Information You Provide to Us: This includes personal details you voluntarily submit through our website or other communications. For example, when you fill out a contact or inquiry form, call or email us, or otherwise communicate with us, we may collect your name, email address, phone number, and any other information you choose to provide in your message. We do not ask for or intentionally collect sensitive personal information (such as financial information, social insurance numbers, or health data) through our website beyond what you provide in basic inquiries. Please only provide personal information that is necessary for your request.
  
  
• Information Collected Automatically: Like most websites, we gather certain technical and usage data automatically when you visit our site. This may include your IP address, browser type, device identifiers, pages viewed, the dates/times of access, and referring website addresses. We collect this data through cookies, scripts, and similar tracking technologies as described below. This information helps us understand how our website is used and improve the user experience, and while it may be linked to you (as an "identifiable individual"), it generally remains aggregated or pseudonymized in our analysis.
  
  

Cookies and Tracking Technologies: Cookies are small text files placed on your device when you visit a website. We use cookies and similar technologies (such as Google Analytics and Google Tag Manager scripts) to enhance site functionality and analyze usage of our site. For instance, Google Analytics uses cookies to collect information on how visitors use our site, which we use to compile reports and improve the site. These cookies may track details like how you navigated our pages and interacted with content. You can refuse or disable cookies through your browser settings; however, note that some features of the site may not function properly without cookies. (See Opt-Out Options below for how you can control or opt-out of certain tracking).

We do not knowingly collect personal information from children under the age of 13. Our website and services are intended for a general audience and not directed at children. If you are a parent or guardian and believe your child has provided personal information, please contact us so we can remove the data.

Methods of Data Collection

We collect personal information through a few different methods, consistent with the principles of consent and transparency:

• Direct Collection (Voluntary): You provide information directly to us. This happens, for example, when you type in and submit your details in a contact form, subscribe to a newsletter, or communicate with us via phone or email. In these cases, you choose to share personal data with us (such as your name, contact info, and the content of your inquiries) and we collect it with your consent.
  
  
• Automated Collection: We also collect some information automatically as you interact with our website. As noted above, we use cookies and tracking technologies to gather technical data about your visit (e.g. IP address, browser type, pages visited, and clicks). This automated collection happens in the background through tools like Google Analytics. The data collected in this manner helps us understand usage patterns and improve our site functionality. We treat any such automatically-collected data as personal information if it can be reasonably linked to an individual, and we ensure users are informed of this automated data gathering (for example, via this Policy and any cookie notices).
  
  
• Third-Party Sources: In general, we do not obtain personal information about you from third-party sources without your consent. The personal data we process is typically collected directly from you or through your use of our site. If in the future we receive information about you from third parties (for example, if you engage with us via a social media platform and that platform shares your info with us), we will handle that information in accordance with this Policy and any consent you have provided.
  
  

By limiting our collection methods to those above, we adhere to PIPEDA’s principles of obtaining information by fair and lawful means and collecting only what is necessary for identified purposes. We will not collect additional categories of personal data or use methods that have not been disclosed to you without updating this Policy or obtaining any required consent.

How We Use Your Personal Data

We use the personal information we collect for purposes that a reasonable person would consider appropriate in the context of your relationship with us. In particular, we may use your personal data for the following purposes:

• To Provide and Improve Our Services: We use your information to respond to your inquiries, requests, or customer service needs. For example, if you fill out a contact form requesting information about our products/services, we will use your name and contact details to get back to you with a response. We may also use information to personalize or improve our offerings and user experience. Any personal information collected will be used only for the purposes for which you provided it, or purposes that are reasonably compatible with those initial reasons (such as keeping a record of our communications with you to better serve you in the future).
  
  
• Communication and Updates: With your consent, we may use your contact information to send you important notices or administrative messages about our services. For example, we might notify you about changes to our services, this Privacy Policy, or other terms. If you have subscribed to a newsletter or opted in to receive promotional emails, we will use your email address to send you news, offers, or other marketing communications. (You can opt out of marketing communications at any time – see Opt-Out Options below.)
  
  
• Analytics and Website Improvements: We process usage data (largely in aggregate form) to understand how our website is used and to improve its content, layout, and performance. Services like Google Analytics help us analyze site traffic and visitor behavior patterns. These insights inform us about what content is most useful to visitors or if any pages are experiencing technical issues, thereby enabling us to enhance the user experience. Data used for analytics is typically aggregated or anonymized. When Google Analytics is used, Google may process certain data (like your IP address and device info) to provide us with reports; we ensure this use is only for our internal analysis and improvement purposes.
  
  
• Legal and Compliance: In certain cases, we may need to use your personal information to comply with applicable laws, regulations, legal processes or enforceable governmental requests. For instance, we may retain transaction records or communications as required by law, or use and disclose information as necessary to protect our rights, privacy, safety, or property, or that of our users or others; to detect and prevent fraud; or to address security or technical issues.
  
  

We will not use your personal information for new, unrelated purposes without first updating this Privacy Policy and, if required by law, obtaining your consent. We aim to clearly identify the purposes for which we collect personal data at or before the time of collection, and we limit our use of the data to those legitimate purposes.

Data Sharing and Disclosure

We do not sell or rent your personal information to third parties for their own marketing or other independent use. However, in the course of running our business and providing our services to you, we may need to share your information with certain trusted third parties, as described here:

• Service Providers: We may disclose personal information to third-party service providers and partners who perform services on our behalf. This includes, for example, companies that provide website hosting, data storage, email delivery, analytics services (such as Google for Google Analytics), customer support, or other administrative services. These third parties are given access to the information only as necessary to perform their functions and are contractually obligated to maintain the confidentiality and security of your data. In other words, they may only use your information for the purposes of providing services to us and not for their own purposes. If we transfer personal information to a service provider (including those located outside of Canada) for processing, we remain accountable for that information and ensure a comparable level of protection through contractual or other means, as required by Canadian law.
  
  
• Business Transactions: If we undergo a business transaction such as a merger, acquisition, reorganization, or sale of all or a portion of our assets, user information (which may include your personal data) might be among the transferred assets. In such cases, your personal information would remain subject to the protections of this Privacy Policy, and we would notify you or post a notice on our website if a transfer affects your personal information in a materially new way.
  
  
• Legal Requirements and Protection: We may disclose personal information to third parties (such as courts, law enforcement or government agencies) if we believe that such disclosure is necessary to:
  
  
• Comply with any applicable law, regulation, legal process, or government request (such as a subpoena or court order).
  
  
• Enforce our website terms of service or other agreements, or investigate potential violations thereof.
  
  
• Detect, prevent, or address fraud, security, or technical issues.
  
  
• Protect the rights, property, or safety of our company, our users, or the public, as required or permitted by law.
  
  
• Aggregated or De-Identified Data: We may share information that has been aggregated or anonymized (so it does not identify you personally) with third parties. For example, we might publish reports or share statistics with business partners that show usage trends on our site (e.g., total number of website visitors, general demographic breakdowns) without revealing any individual's identity. This type of data does not constitute personal information and may be used freely.
  
  

We believe in transparency when it comes to how and with whom your information is shared. If we share any personal data with external parties, we will declare who we share it with and why in this Policy. Other than the limited instances described above, we will not disclose your personal information to third parties without your knowledge or consent, unless required or permitted by law.

Data Storage, Maintenance, and Protection

We take the security and proper handling of your personal information seriously. Below is how we store, maintain, and safeguard the data we hold:

• Storage Locations: Your personal information is stored on secure servers operated by us or our service providers. These may be located in Canada or in other jurisdictions. In particular, some data (such as analytics information via Google Analytics or cloud backups) may be processed and stored on servers in the United States or other countries. Cross-Border Transfers: If your information is transferred outside of Canada for processing or storage, it may be subject to the laws of the foreign jurisdiction (for example, information stored in the U.S. may be accessed by U.S. law enforcement under U.S. laws). However, we remain responsible for protecting your personal data and will take all reasonable steps to ensure that any overseas service providers handle your information with a level of security and privacy protection comparable to that required in Canada. By using our site or providing information to us, you understand that your personal information may be transferred to and stored in other countries as explained above.
  
  
• Retention and Maintenance: We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by law. This means your information will be kept for the duration of our relationship and thereafter only as long as needed for purposes such as maintaining records (for example, for our legitimate business needs, accounting requirements, or to comply with legal obligations). When personal information is no longer necessary or relevant for our identified purposes and no legal retention requirements apply, we will anonymize, securely delete or destroy that information. We also strive to keep the personal information we hold accurate, complete, and up-to-date as needed for its intended use. We rely on you to help us maintain accuracy – if your information changes or if you believe our records are inaccurate, please contact us so we can update your data.
  
  
• Protection and Security Measures: We employ appropriate administrative, technical, and physical safeguards to protect the personal information in our custody or control against loss, theft, and unauthorized access, use, alteration, or disclosure. These measures include, for example, secure network firewalls, encryption of data transmissions (e.g., our website is secured via HTTPS/TLS), access controls to databases containing personal data (restricted to personnel who have a legitimate need to access the information for the purposes described), and regular software security updates. We also ensure any third-party service providers handling personal data on our behalf implement comparable security measures. While we follow generally accepted industry standards to protect personal information, please be aware that no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security of information. In the unlikely event of a data breach that poses a real risk of significant harm, we will notify affected individuals and relevant authorities as required by law.
  
  

By safeguarding your data in these ways, we adhere to PIPEDA's security safeguard principles, which require protection measures appropriate to the sensitivity of the information. If you have any questions about our specific data security practices, feel free to contact us (see Contact Us section below).

Your Rights

We respect your rights to control your personal information. Under Canadian privacy laws (like PIPEDA), you have various rights regarding the personal data we hold about you. We outline those key rights here and how you can exercise them:

• Right to Access: You have the right to request access to the personal information we have about you. This means you can ask us to confirm whether we are processing your personal data and to provide you with a copy of that data, as well as information about how it’s being used and with whom it has been shared. We will respond to access requests within a reasonable timeframe and as required by law. There may be limited circumstances in which we cannot provide access (for example, if it would reveal personal information about another individual or if it is subject to legal privilege), but we will explain any such situation to you.
  
  
• Right to Correction: If any of your personal information we hold is inaccurate or incomplete, you have the right to request that we correct or update it. We encourage you to help us keep your information up-to-date by notifying us of any changes. Upon request and where you demonstrate the information is incorrect, we will amend the information as required. If we have shared the incorrect information with third parties, we will (where practical) notify them of the correction as well.
  
  
• Right to Withdraw Consent: Where our processing of your personal information is based on your consent, you have the right to withdraw that consent at any time. For example, if you consented to receive marketing emails, you can opt out later (see Opt-Out Options below). If you provided contact information and no longer want us to hold or use it, you can request we delete it from our records (provided we do not need to retain it for legal or business reasons). Please note that withdrawing consent will not retroactively undo any processing that was already done while your consent was in effect, and it may affect our ability to continue providing you with certain services. We will inform you if this is the case.
  
  
• Right to Object or Restrict (Applicable in certain jurisdictions): In some cases, you may have a right to object to or ask us to restrict the processing of your personal information. For instance, if you feel we are processing information in a way that is not compatible with the purposes for which it was collected, you can raise this with us. We will consider such requests and respond as required by applicable law.
  
  
• Right to Complain: We take your privacy rights seriously. If you have a concern or complaint about how we are handling your personal information, you have the right to file a complaint with us (see Contact Us below for how to reach our privacy officer). We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal information. If after contacting us you feel that we have not adequately addressed your privacy concerns, you may escalate the matter to the Office of the Privacy Commissioner of Canada or your provincial Privacy Commissioner, as applicable. We will provide you with the contact information for the appropriate privacy commissioner upon request.
  
  

We will not discriminate against you for exercising any of these rights. These rights are subject to certain limitations and exceptions under applicable law. To exercise any of your rights described above, please contact us (see Contact Us section). We may take steps to verify your identity before fulfilling your request, to protect your privacy and security.

Opt-Out Options

We provide you with choices to opt out of certain data uses, communications, or collection mechanisms. Here are the primary opt-out options available to you:

• Opt-Out of Marketing Communications: If you have subscribed to our newsletter or otherwise agreed to receive promotional communications from us, you can opt out at any time. To stop receiving marketing or promotional emails, you can click the "unsubscribe" link at the bottom of any of these emails. You can also contact us directly (via the contact information below) to request removal from our mailing list. Once we process your opt-out request, we will stop using your email address for marketing purposes. Please note that even if you opt out of marketing messages, we may still send you transactional or administrative emails (for example, responses to your inquiries or notifications about your account or our ongoing business relations, if any).
  
  
• Cookies and Analytics Tracking: As described earlier, we (and third-party analytics providers like Google) use cookies to collect usage data. You have the right to opt out of or limit this tracking:
  
  
• You can set your web browser to refuse all or some cookies, or to alert you when cookies are being sent. Each browser is different, but look at your browser's Help or Settings menu for instructions on how to manage cookies. Please be aware that if you disable cookies in your browser, some features of our site may not work correctly.
  
  
• Google Analytics Opt-Out: Google provides an opt-out mechanism for Google Analytics if you do not want your site activity to be available to Google Analytics. You can install the Google Analytics Opt-out Browser Add-on for your web browser. This add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and gtag.js) from sharing information with Google Analytics about visit activity. Using this tool will opt you out of all websites using Google Analytics, not just ours. (For more information on opting out of Google Analytics tracking, you may visit Google's website.)
  
  
• We believe in making these opt-out options clear because if we use cookies or similar technologies, we must inform users and give them a way to opt out of such data collection. There is no adverse effect on our services if you choose to opt out of analytics tracking – you will still be able to use the website normally.
  
  
• Do Not Track (DNT) Signals: Some web browsers offer a "Do Not Track" feature that signals to websites that you do not want to be tracked across different sites. At this time, our website does not respond to DNT signals. This is because there is not yet a common industry standard for how to interpret DNT signals. We will update this Privacy Policy if that changes in the future. Nonetheless, you can use the other opt-out methods described here to control targeted advertising and tracking.
  
  
• Targeted Advertising Preferences: We do not currently serve targeted advertisements on our site (and we do not share your data with third parties for their ad purposes). If this changes in the future, we will provide appropriate notice and opt-out mechanisms (such as links to industry opt-out sites like the Digital Advertising Alliance of Canada’s opt-out page). For now, if you see any ads related to us on other platforms, they are likely generic or based on aggregated data, not on personal data from our site. You can manage general ad preferences through settings provided by many ad networks and social media platforms.
  
  

If you have any questions about opting out of any data collection or if you need assistance with any of the above, please contact us. We are here to help you make informed choices about your personal information.

Changes to This Privacy Policy

We may modify this Privacy Policy from time to time, for example to reflect changes in our practices, to keep up with new legal requirements, or to improve clarity. When we update the policy, we will revise the "Last Updated" date at the top. Any changes will become effective when we post the revised Privacy Policy on our website. We will not reduce your rights under this Privacy Policy without your explicit consent. If changes are material, we may also provide a more prominent notice (such as adding a statement on our homepage or sending you a notification, if we have your contact information) that the Privacy Policy has been updated.

Your continued use of our website or services after any changes to this Privacy Policy signifies your acceptance of the updated terms (to the extent permitted by law). We encourage you to review this Policy whenever you visit our site to stay informed about how we protect your information. Maintaining an up-to-date privacy policy and aligning it with our actual data practices is an important part of our commitment to transparency and privacy compliance.

Contact Us

We welcome any questions, concerns, or requests regarding this Privacy Policy or our personal information practices. FreshSites has appointed a privacy officer (or designated contact) who is accountable for our compliance with this Policy and applicable privacy laws. If you would like to exercise your rights, ask a question, or file a complaint, please reach out to us:

FreshSites
Email: info@freshsites.ca

When you contact us, please provide your contact information and a clear description of your request or concern. We will respond to inquiries or complaints within a reasonable timeframe. If you are making a request to access or correct your data, we may need to verify your identity for security purposes before acting on your request.

If you are not satisfied with our response to a privacy-related matter, you have the right to contact the Office of the Privacy Commissioner of Canada (or your provincial Privacy Commissioner, if applicable) and file a complaint. We will provide guidance on how to contact the appropriate regulator upon request.

Thank you for reading our Privacy Policy. We value your trust and are committed to protecting your personal information.