Privacy Policy
Last Updated: January 1st, 2025
Introduction
1. This Privacy Policy Statement (the “Privacy Policy”) contains the policies, procedures and practices to be followed by Tradecon Services Inc. and any of its present or future subsidiaries (the “Company”) pertaining to the collection, use and disclosure of personal information (the “Personal Information”) of an identifiable person (the “Individual”) that is a present, future or former user (the “User) of the Company’s services or affiliated services.
2. The Company recognizes the confidential nature of the Personal Information in its care and is accountable for the compliance of itself and its directors, officers, management, employees, representatives and agents including consultants and independent contractors (the “Staff”) in protecting this Personal Information.
3. For the purpose of this Privacy Policy, the term “Personal Information” has the meaning of any information or collection of information in any form, whether oral, electronic or written that pertains to the Individual excluding information that is publicly available in its entirety. Personal Information will also include any publicly available information that is combined with non-publicly available information.
4. Personal Information includes but is not limited to name, home address, home phone number, home email address, identity verification information, Social Insurance Number, physical description, age, gender, salary, education, professional designation, personal hobbies and activities, medical history, employment history, and credit history.
5. Personal Information will not include the Individual's business title, and business address and contact information when used or disclosed for the purposes of reasonable business communication.
6. The Company will implement policies and procedures that give effect to this Privacy Policy including procedures to protect and secure Personal Information, procedures to receive, investigate and resolve complaints, procedures to ensure adequate training of the Staff concerning the Company's privacy policies, and procedures to distribute new and current information pertaining to the Company's Privacy Policy.
Corporate Privacy Policy
7. The Company and the Staff will at all times respect the confidentiality of the Personal Information placed in its care. The Company will endeavour to ensure that the policies affecting the collection, storage and disclosure of Personal Information reflect the confidential nature of the information.
8. The Company will comply with all applicable privacy legislation and regulations in force now and in the future related to protecting the confidentiality of Personal Information.
Purposes for which Personal Information is Collected and Used
9. Personal Information will be collected, used and disclosed for purposes of providing Individuals with access to and use of the Company’s services, website, and related applications, including administering payments, obtaining contractor reviews, complying with applicable laws. In addition, the Company collects and uses personal information in the following circumstances:
(i) Contractor ID Verification and Background Checks: Contractors who wish to perform site visits must complete a third-party ID verification and may choose to complete a criminal background check on an optional basis. The Company will obtain the contractor’s consent prior to conducting an ID verification or optional criminal background check. To verify a contractor’s identity, a third-party collects a photo of the front and back of the contractor’s driver’s license or other photo ID, and a selfie that the contractor takes of themselves. The third-party uses the contractor’s selfie and the photo on the contractor’s driver’s license to verify that the contractor is who they say they are. The contractor’s selfie and the photos of the contractor’s driver’s license are only kept as long as is needed to complete the verification process.
(ii) Contractor Site Visits: During site visits, contractors may collect Personal Information such as photos, home measurements, and homeowner project plans and preferences for purposes such as developing plans for a project, determining which materials are required, and recording homeowner instructions and preferences.
(iii) Purchasing Materials: When homeowners and contractors purchase materials for their projects through the Company website, the Company (or the Company’s authorized third-party payment processor) will collect information such as the purchaser’s first and last name, email address, phone number, mailing address, delivery address, and payment information (including billing address, credit card number, expiry date and CVV/CVC code) in order to process the transaction.
(iv) Pre-Approved Loans: Homeowners provide consent to assess their eligibility for home renovation loans offered by third party partners. In order to assess eligibility, the Company uses information such as the Homeowner’s name and address, phone number, and project details.
10. The purposes for collecting Personal Information will be documented by the Company. Personal Information will only be used for the stated purpose or purposes for which it was originally collected unless you otherwise consent. The purposes for which Personal Information is being collected will be identified orally or in writing to the Individual before it is collected. The person collecting the information will be able to explain the purpose at the time that the information is collected.
11. The Company may use Personal Information for a purpose other than the originally stated purpose where the new purpose is required by law or where the Company has obtained consent in writing from the affected Individual for each new purpose.
Knowledge and Consent
12. Knowledge and consent are required from the affected Individual for the collection, use and disclosure of all Personal Information subject to exceptions noted elsewhere in the Privacy Policy statement.
13. Consent will not be obtained through deception or misrepresentation.
14. Any use or disclosure of Personal Information will be within the reasonable expectations of the Individual.
15. Subject to legal and contractual obligations, an Individual may withdraw their consent on reasonable notice.
Legislation and Regulation
16. Where the Company’s Users are living in different jurisdictions the specific rights and obligations of Users may vary between jurisdictions.
17. The Company is subject to the privacy legislation in all jurisdictions in which the Company operates. If any term, covenant, condition or provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid, void or unenforceable, it is the intent of this Privacy Policy that the scope of the rights and obligations of the Privacy Policy be reduced only for the affected jurisdiction and only to the extent deemed necessary under the laws of the local jurisdiction to render the provision reasonable and enforceable and the remainder of the provisions of the Privacy Policy statement will in no way be affected, impaired or invalidated as a result.
18. Where this Privacy Policy provides greater rights and protections to the Individual than the available governing law, the terms of this Privacy Policy will prevail wherever allowed by law.
Scope and Application
19. The rights and obligations described in this Privacy Policy will apply to all Individuals. The Company and the Staff must comply with the policies, procedures and practices described in the Privacy Policy.
Collection of Personal Information
20. The type and amount of Personal Information collected by the Company will be limited to the minimum necessary to accomplish reasonable business purposes. Personal Information will not be collected maliciously, indiscriminately or without a reasonable business purpose.
21. Personal Information will be collected using fair and lawful means.
Access by Authorized Company Representatives
22. All Personal Information will be released internally only on a need-to-know basis. In the course of normal and reasonable business practices it is the policy of the Company to grant designated Company representatives access to Personal Information files. This access will not exceed that necessary to accomplish the specific business function of the Company representative nor the purpose for which the information was originally collected.
Accuracy of Personal Information
23. The Company will endeavour to ensure that all Personal Information collected is accurate and validated using reasonable business practices and procedures. The Company is also committed to ensuring that the Personal Information remains accurate for the purpose for which it was collected.
Rights of Access and Correction
24. The Company will make reasonable efforts to ensure that Personal Information is at all times complete and accurate for its stated purpose.
25. An Individual may apply for access to their Personal Information by submitting a request in writing along with adequate proof of identity to an authorized personnel officer. Where the application is made in person the requirement for proof of identity will be at the discretion of the personnel officer. The Individual will be provided with a copy of all available information that is not subject to restriction as described in this Privacy Policy. All Personal Information will be provided at no cost or at a minimal cost that is not prohibitive.
26. The Company will also provide a specific summary of how the Personal Information has been used and to whom it has been disclosed. Where a detailed account of disclosure is not available, the Company will provide a list of organizations to which the Personal Information may have been disclosed.
27. The Personal Information disclosed to an Individual must be in a form that is reasonable and understandable. Where the meaning of information is not clear then translations and explanations will be provided without additional cost.
28. Where an Individual suspects that an error exists in their Personal Information, the Individual may submit a request in writing for correction. This request should include any relevant information substantiating the error and should describe the correction to be made. The Company will make all reasonable efforts to address any request for correction.
29. Where the Individual successfully demonstrates an error in their Personal Information the Company will make appropriate corrections. Any modifications, additions or deletions to the Individual's Personal Information will be made only by an authorized personnel officer.
30. Where a request for correction is not successful, the details and substantiating evidence of the request will be recorded and retained by the Company.
31. The Company will endeavour to respond promptly to any reasonable request for disclosure and correction made by an Individual to ensure the continued accuracy of Personal Information.
32. In some instances the Company may be required to limit access to Personal Information because of statutory or regulatory requirements. In all instances however the Company will make all reasonable efforts to comply with the Individual's request for access and correction to the extent of what is allowed by statute or regulation.
33. The Company may refuse access to portions of the Personal Information of an Individual where it is found to contain Personal Information pertaining to another Individual.
Withdrawing Consent
34. An Individual may request deletion of their Personal Information (including information outside their profile record) or withdraw their consent to the Company’s collection, use and disclosure of their Personal Information by emailing or writing to the Company’s Chief Executive Officer at the contact information set out below.
Please note that if you withdraw your consent, certain personal information may need to be retained to meet the Company’s legal, regulatory and contractual obligations.
Disclosure of Personal Information
35. The Company and the Staff will keep confidential all Personal Information in its control. However, the Company may choose to transfer or disclose Personal Information in the following circumstances:
(a) to certain third parties that provide services on the Company’s behalf. The Company uses service providers to provide services such as material providers, processing payments, verifying ID, providing criminal background checks, and providing advertising, analytics and marketing services. The Company’s service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose Personal Information for their own marketing or other purposes. The Company’s service providers may be located in the U.S., Canada or other foreign jurisdictions;
(b) with consent, to contractors or other partners, including third party material providers;
(c) where the Individual who is the subject of disclosure has provided consent;
(d) where the disclosure is in accord with the purposes for which the Personal Information was originally collected;
(e) where the disclosure is for the purpose of providing employment references to prospective employers and where the Personal Information disclosed is limited to information considered reasonably necessary for the purpose of providing employment references;
(f) where the Company is permitted or required to do so by applicable legislation or regulation;
(g) where the disclosure is required by authorized government representatives who are acting to enforce any federal, provincial or territorial law or carrying out an investigation relating to the enforcement of any federal, provincial or territorial law or gathering information for the purpose of enforcing any federal, provincial or territorial law;
(h) where the Company is required to comply with valid court orders, warrants or subpoenas or other valid legal processes (which may include lawful access by US or foreign courts, law enforcement and national security authorities) and
(i) in an emergency to protect the physical safety of any person or group of persons.
(j) for sell, trade, or otherwise to third-party partners for various purposes including, but not limited to, marketing, business analytics, research, data aggregation, and the improvement of services and products. Types of personal information that may be sold include your name, email address, home address, phone number, and other data collected through the Tradecon platform. Your personal information may be sold to partners in sectors such as marketing and advertising agencies, data analytics companies, research institutions, financial institutions, technology companies, e-commerce platforms, and other businesses that offer products or services that may be of interest to you. By using Tradecon’s services, you explicitly consent to the sale of your personal information for these purposes.
Ownership of Personal Information
36. All Personal Information collected by the Company in compliance with this Privacy Policy are business records of the User.
Retention and Disposal of Personal Information
37. The Company has Personal Information retention processes designed to retain Personal Information for no longer than necessary for the purposes for which it was collected and as set out in this Privacy Policy Statement, or to otherwise meet legal requirements.
38. With respect to Staff Personal Information, any Personal Information collected by the Company will be retained by the Company during the period of active employment of the Individual as well as during the post-employment period only as long as the Personal Information is required to serve its original purpose or as directed by applicable legislation or regulation.
39. Personal Information that is no longer needed for its stated purpose will be destroyed, erased or made anonymous.
40. The Company will ensure that all practices and procedures relating to the disposal of Personal Information will respect the fundamental policy of confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, will ensure the complete destruction of Personal Information so that there will be no risk of subsequent unauthorized disclosure of Personal Information.
Deceased Individuals
41. The rights and protections of the Company's Privacy Policies will extend to deceased Individuals.
Security
42. The Company will take and enforce all reasonable security measures appropriate for the sensitivity of the information to ensure that all Personal Information for every Individual is protected against any form of unauthorized use including but not limited to accidental or malicious disclosure, unauthorized access, unauthorized modification, unauthorized duplication or theft.
43. Methods of security will include but not be limited to the following:
(a) physical security including locked filing cabinets and secure-access offices;
(b) organizational security including security clearances and access limited on a “need-to-know” basis and
(c) technological security including passwords and encryption.
44. The Company will educate and inform all Staff regarding the Privacy Policy and related procedures and on the importance of confidentiality of Personal Information and will monitor compliance with the Privacy Policy and may observe and investigate the information management practices of all Staff having care of Personal Information.
Knowledge of Unauthorized Disclosure
45. Responsibility for the security of Personal Information is a responsibility that the Company holds in very serious regard. Any Staff having knowledge of an impending unauthorized disclosure, whether intentional or unintentional, and who fail to act to prevent the unauthorized breach will be subject to sanction as described in the Enforcement section of this document including the immediate dismissal of the offending Staff.
Enforcement
46. All Staff having care over Personal Information must comply with the policies, procedures and practices described in the Privacy Policy. Any breach of any term or condition of this Privacy Policy, whether intentional or unintentional, including but not limited to the unauthorized disclosure of Personal Information is grounds for disciplinary action up to and including the immediate dismissal of any and all responsible Staff. Any breach of any term or condition of this Privacy Policy, whether intentional or unintentional, is grounds for dismissal with cause.
Compliance with Privacy Policy
47. The Company will have a procedure that will allow Individuals to challenge the Company's compliance with this Privacy Policy. The Company will also have procedures to promptly respond to Privacy Policy compliance challenges.
48. The Company will make all reasonable efforts to investigate and respond to compliance challenges relating to this Privacy Policy. Where a challenge is well founded the Company will take action to correct any outstanding problems up to and including amending the Privacy Policy and related procedures.
Arbitration
49. In the event a dispute arises out of or in connection with this Privacy Policy, the parties will first attempt to resolve the dispute through friendly consultation. If the dispute is not resolved within a reasonable period, then any or all outstanding issues may be submitted to final and binding arbitration in accordance with the laws of the Province of Ontario. The arbitrator's award will be final, and judgement may be entered upon it by any court having jurisdiction within the Province of Ontario.
Contact Us
If an Individual has any questions or comments about this Privacy Policy Statement or the manner in which the Company or its service providers (including its service providers outside Canada) treat the Individual’s Personal Information, or to request access to, or correction or deletion of, the Individual’s Personal Information, the Individual may contact the Company at:
Matthew Zemel
Chief Executive Officer
+1 (647)-960-7525
info@tradeconservices.com