Privacy Statement

Brafton, Inc. (“Brafton” or “we”) respects your privacy and is committed to protecting it through our compliance with this statement and applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and, where applicable, provincial privacy legislation.

This Privacy Statement (“Statement“) describes the types of Personal Information, as defined below, we may collect from you or that you may provide when you visit our websites, including www.brafton.ca, whether through a computer or on a mobile device. This Statement applies to the collection, use, and disclosure of Personal Information provided by Brafton’s customers and users of Brafton.ca (“you” or “your“).

Brafton is responsible for Personal Information under its control and has designated a Privacy Officer accountable for compliance with this Statement.

Please read this Statement carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By using Brafton.ca, you acknowledge that you have read and understand this Statement. Where required by law, we will obtain your consent to the collection, use, and disclosure of your Personal Information.

If you do not agree with our policies and practices, your choice is not to visit Brafton.ca. This Statement may change from time to time. Your continued use of the Brafton Solution(s) after we make changes is deemed to be acceptance of those changes, so please check the Statement periodically for updates.

If you have any questions about this Privacy Policy or how we manage the information that you provide us, please email us at privacy@brafton.ca or write to us at Brafton Inc, 2 Oliver Street, Suite 904, Boston MA 02109.

COLLECTION

This Statement applies to Personal Information we collect:

On Brafton.ca whether on a computer or a mobile device;
In email, text, and other electronic messages between you and Brafton, Inc.

“Personal Information” means information about an identifiable individual, as defined under applicable Canadian privacy laws.

Personal Information does not include:

Publicly available information from government records;
Information that has been anonymized or aggregated so that it cannot be used to identify an individual;
Information excluded from the scope of applicable privacy laws.

In particular, Brafton has collected and processed the following categories of Personal Information within the last twelve (12) months:

Category: Examples (not intended to be exhaustive)

Identifiers: Real name; postal address; email address; telephone number; IP address; device identifiers; employment information; browser and network information.
Internet activity: Interaction and behavior tracking on site, including use of cookies.
Geolocation data: General location information derived from IP address or device usage.

Brafton obtains the categories of Personal Information listed above from the following sources:

Directly from you: Information you provide via forms or communications.
Indirectly from you: Observations of your interactions with our website.
Correspondence: Records of communications, including email.
Third-party sources: Business contact information from providers such as ZoomInfo or similar services for marketing purposes.

COOKIES AND TRACKING TECHNOLOGIES

The technologies we use for data collection may include:

Cookies: Small files placed on your browser or device. You may refuse cookies through your browser settings.
Analytics and marketing tools: Including Google Analytics, HubSpot, LinkedIn and Meta.

Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device.

USE OF YOUR PERSONAL INFORMATION

(1) How We Use Your Personal Information

We identify the purposes for collecting Personal Information at or before the time of collection.

We collect, use, and disclose Personal Information for the following purposes:

To operate, maintain, and improve our website and services;
To understand website usage and marketing performance;
To communicate with you, including responding to inquiries;
To provide marketing communications (where permitted by law or with your consent);
To comply with legal and regulatory obligations.

We will only use your Personal Information for the purposes for which it was collected or for purposes that are consistent with those purposes, unless otherwise permitted or required by law.

Brafton does not sell Personal Information. We may disclose Personal Information:

To service providers who assist us in operating our business (subject to contractual safeguards);
To comply with legal obligations or respond to lawful requests;
To enforce agreements or protect our rights.

We require service providers to protect Personal Information and to use it only for the purposes for which it was disclosed.

Consent

We obtain your consent for the collection, use, and disclosure of Personal Information, except where otherwise permitted or required by law. Consent may be express or implied, depending on the sensitivity of the information and the context.

You may withdraw your consent at any time, subject to legal or contractual restrictions, by contacting us at privacy@brafton.ca.

Choices About How We Use and Disclose Your Personal Information

We provide you with choices regarding your Personal Information:

Tracking Technologies: You may disable cookies through your browser settings.
Marketing Communications: You may unsubscribe via email links or by contacting privacy@brafton.ca.

SECURITY

We have implemented appropriate technical and organizational safeguards to protect Personal Information against loss, theft, unauthorized access, disclosure, copying, use, or modification.

The safety of your Personal Information also depends on you. Where you use passwords, you are responsible for keeping them confidential.

While we use reasonable safeguards, no method of transmission over the Internet is completely secure.

RETENTION

We retain Personal Information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. When no longer required, Personal Information is securely deleted or anonymized.

CROSS-BORDER TRANSFERS

Brafton operates in Canada and the United States. Personal Information may be processed or accessed outside of Canada, including in the United States and other jurisdictions, where it may be subject to access by courts, law enforcement, and regulatory authorities in accordance with local laws.

We use contractual and other safeguards to protect Personal Information when it is transferred across borders.

OTHER INFORMATION

Our website is not intended for children, and we do not knowingly collect Personal Information from individuals under the age of 13.
Third parties may use cookies in your browser to enable targeted advertising. You can opt out of interest-based advertising through the Digital Advertising Alliance of Canada at www.youradchoices.ca.

PERSONAL INFORMATION RIGHTS

Under Canadian privacy laws, you have the right to:

Access the Personal Information we hold about you;
Request corrections to inaccurate or incomplete information;
Withdraw consent (subject to limitations);
Request information about how your Personal Information is used or disclosed;
Request information about third parties to whom your Personal Information has been disclosed, where required by law.

To exercise these rights, please contact privacy@brafton.ca.

We will respond to requests within the timeframes required by applicable law.

ACCOUNTABILITY AND CONTACT

Brafton is responsible for Personal Information under its control and has designated a Privacy Officer responsible for compliance with this Statement.

If you have questions, concerns, or complaints, please contact:

Email: privacy@brafton.ca
Mail: 7030 Woodbine Avenue Suite 500, Markham, ON L3R 6G2

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

CHANGES TO OUR PRIVACY STATEMENT

Brafton reserves the right to amend this Statement at any time. Updates will be posted on this page.

Last Updated and Effective: March 2026