ETTRICS PRIVACY POLICY

Gardenbook Inc. o/a Ettrics
Effective Date: May 6, 2025

1. Introduction

Gardenbook Inc., operating as Ettrics (“Ettrics”, “we”, “us”, or “our”), is committed to protecting the privacy of our clients and visitors. This Privacy Policy outlines how we collect, use, disclose, and protect personal information through our website at https://ettrics.com/ (the “Website”) and through our cross-functional design, technology, marketing, and data creative services (the “Services”) offered to our clients (“Clients”). By accessing our Website or using our Services, you acknowledge and consent to the practices described in this Privacy Policy.

2. Scope of This Privacy Policy

This Privacy Policy applies to personal information, defined as data that can identify an individual (“Personal Information”), collected from visitors to the Website and our Clients (“Customers”). It does not cover the practices of third parties we do not own or control, including third-party services linked to our Website or Services.

3. Collection and Use of Personal Information

3.1 Personally Identifiable Information

When you register for our Services, inquire about engaging Ettrics, or interact with our Website, we may collect Personal Information, including:

  • Name
  • Company name
  • Email address
  • Phone number
  • Business address
  • Billing information (e.g., credit card number and billing address)
  • Third-party account credentials (e.g., hosting or application access) provided by you

We also collect information you provide through:

  • Website forms or uploads
  • Linked third-party services (e.g., HubSpot, Google)
  • Email communications, which may be retained, including your email address and message content

Purposes of Collection: We use Personal Information to:

  • Deliver and manage the Services you request
  • Communicate about Services, respond to inquiries, and provide updates
  • Send newsletters, thought leadership content, event invitations, or other news
  • Process billing and payments
  • Improve our Website and Services
  • Other purposes, with your consent, as notified at the time of collection

You may choose not to provide certain Personal Information, but this may limit your ability to access all Services or features.

3.2 Non-Personally Identifiable Information

We may collect non-personally identifiable information, such as:

  • Aggregated Website usage data (e.g., number of visitors, pages visited, session duration)
  • Data collected via cookies, web beacons, or similar technologies

This data is used to:

  • Analyze usage patterns and improve user experience
  • Tailor advertising through third-party partners (using non-personally identifiable information)
  • Monitor and enhance Website performance

Aggregate data may be shared with third parties for analytical or marketing purposes but is not intended to identify individuals.

4. Storage and Transfer of Personal Information

Personal Information is processed and stored on secure servers in Canada and the United States. We may transfer data to third-party service providers in these or other jurisdictions to support our Services. By using our Website or Services, you consent to the transfer, storage, and processing of your Personal Information in these locations, where it may be subject to local lawful access regimes or court orders.

5. Disclosure of Personal Information

We do not rent or sell your Personal Information. We may disclose it only as follows:

5.1 Ettrics Personnel and Service Providers

We may share Personal Information with our employees, contractors, or third-party service providers to perform tasks on our behalf (e.g., hosting, payment processing, or analytics). These parties are restricted to using the information solely for the purpose of providing the requested services.

5.2 Business Transfers

In the event of a merger, acquisition, bankruptcy, or other change of control, Personal Information may be transferred to the new controlling entity, as permitted by applicable law.

5.3 Legal Requirements

We may disclose Personal Information without your consent if required to:

  • Comply with applicable laws, regulations, legal processes, or governmental requests
  • Enforce our contracts or user agreements, including investigating violations
  • Protect our rights, property, or safety, or that of our Clients or others
  • Detect, prevent, or address fraud, security, or technical issues

We may share information with other organizations for fraud protection or spam/malware prevention, as permitted by law.

5.4 With Your Consent

We will seek your consent before using or disclosing Personal Information for purposes not outlined in this Privacy Policy, as required by applicable privacy laws.

6. Data Retention

We retain Personal Information only as long as necessary for the purposes outlined in this Privacy Policy or as required by law. Retention periods may extend beyond the termination of our relationship with you for purposes such as:

  • Fraud prevention
  • Legitimate business needs (e.g., aggregated data analysis)
  • Legal compliance

Retained data remains subject to this Privacy Policy.

7. Rights of European Economic Area (EEA) Residents

If you are located in the EEA, you have rights under the General Data Protection Regulation (GDPR), including:

  • Access: Request a copy of your Personal Data
  • Rectification: Correct inaccurate or incomplete Personal Data
  • Erasure: Request deletion of your Personal Data, subject to legal obligations
  • Restriction: Limit the processing of your Personal Data
  • Data Portability: Receive your Personal Data in a structured, commonly used format
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: Revoke consent for processing, where applicable

To exercise these rights, contact us at privacy@ettrics.com. Where we process Personal Data on behalf of our Clients (as a data processor), you must contact the Client (data controller) directly. We may verify your identity before processing requests. You may also lodge a complaint with your local Data Protection Authority.

8. Access and Correction

You may request access to your Personal Information to verify its accuracy or understand our use of it. Upon written request, we will provide a copy of your Personal Information, except in limited circumstances (e.g., where it involves another individual’s data), as permitted by law. We will explain any denials upon request.

We strive to keep your Personal Information accurate and up-to-date. You may update, correct, or delete your information through mechanisms we provide or by contacting us. Updated information will be shared with authorized third parties, as appropriate.

9. Security

We implement reasonable technical, organizational, and administrative measures to protect Personal Information from unauthorized access, loss, or disclosure. However, no system is completely secure, and we cannot guarantee absolute security.

10. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to enhance your experience, analyze usage, and deliver personalized content. You can manage cookie preferences through your browser settings, but disabling cookies may affect Website functionality. For more details, see our Cookie Policy (to be developed and linked).

11. Children’s Privacy

Our Website and Services are not directed to individuals under 16. We do not knowingly collect Personal Information from children under 16. If you believe we have collected such information, please contact us at privacy@ettrics.com to request its deletion.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be communicated via an announcement on our Website or by email before they take effect. Your continued use of the Website or Services after such changes constitutes acceptance of the updated Privacy Policy.

13. Contact Us

For questions, concerns, or to exercise your rights, contact our Privacy Officer:

  • Ettrics
  • 150 Elgin St Suite 800, Ottawa, ON K2P 2P8
  • Email: privacy@ettrics.com