Privacy Policy

Paction’s Privacy Values

Paction takes your privacy very seriously. Our privacy policy is guided by our privacy values and at the core of that is transparency.

Privacy

We value your privacy. It’s your data, not ours. We all deserve to have our private data kept private. We value the trust that our users place in us by sharing their information with us and appreciate the responsibility we have to maintain that trust.

Protection

You deserve to have your personal data and content protected. We’re dedicated to protecting the information you share with us and invest significant resources to ensure your data is kept secure. Paction believes that each user deserves to have their personal data kept private and confidential without fear of misappropriation or bullying and be free from unwanted targeting by third parties.

Privacy Policy

Last updated: December 1st, 2024

This Privacy Notice for Paction Inc. (“we”, “us”, or “our”) describes how and why we might assess, collect, store, use, and/or share (“process”) your personal information when you use our service (“Services”), including when you:

• Visit our website at https://paction.ca, or any website of ours that links to this Privacy Notice
• Use the Paction Platform. The Paction Platform is an online marketplace that enables registered users to offer certain services related to dog breeding, including the sale of dogs.
• Engage with us in other related ways, including any sales, contests and giveaways, marketing or events.

Questions or Concerns?

Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies or practices, please DO NOT USE OUR SERVICE. If you still have any questions or concerns, please contact us at privacy@paction.ca.

Summary of Key Points

This summary provides key points from our Privacy Notice:

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
• How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.
• What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
• How do you exercise your rights? The easiest way to exercise your rights is by visiting paction.ca/privacy, or by contacting us at privacy@paction.ca. We will consider and act upon any request in accordance with applicable data protection laws.
• What to learn more about what we do with any information we collect? Review the Privacy Notice in full.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On to Process Your Personal Information?
4. When and With Whom Do We Share Your Personal Information?
5. What Is Our Stance on Third-Party Websites?
6. Do We Use Cookies and Other Tracking Technologies?
7. How Long Do We Keep Your Information?
8. How Do We Keep Your Information Safe?
9. Do We Collect Information From Minors?
10. What Are Your Privacy Rights?
11. Controls for Do-Not-Track Features
12. Do We Make Updates to This Notice?
13. How Can You Contact Us About This Notice?
14. How Can You Review, Update, or Delete the Data We Collect From You?

1. What Information Do We Collect?

Personal information you disclose to us.

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Service, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Phone numbers
• Birth dates
• Email addresses
• Mailing addresses
• Passwords
• Billing addresses
• Initials and signatures
• Photos of Government-issued Identification for authentication purposes
• Other contact or authentication data

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy note here: https://stripe.com/en-ca/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information - such as your Internet Protocol (IP) address and/or browser and device characteristics - is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Service. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Service.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user.
• To respond to user inquiries/offer support to users.
• To send administrative information to you.
• To fulfill and manage orders.
• To enable user-to-user communications.
• To request feedback.
• To send you marketing and promotional communications.
• To deliver targeted advertising to you.
• To post testimonials.
• To protect our Services.
• To evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends.
• To determine the effectiveness of our marketing and promotional campaigns.
• To comply with our legal obligations.

3. What Legal Bases Do We Rely On to Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
• For investigations and fraud detection and prevention.
• For business transactions provided certain conditions are met.
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
• For identifying injured, ill, or deceased persons and communicating with next of kin.
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.
• If it is reasonable to expect collection and use with consent would compromise the availability or accuracy of the information and the collection is reasonable for investigating a breach of an agreement or a contravention of the laws of Canada or a province.
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
• If the collection is solely for journalistic, artistic, or literary purposes.
• If the information is publicly available and is specified by the regulations.

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work.

The third parties we may share personal information with are as follows:

• Advertising, Direct Marketing, and Lead Generation: Mailgun
• Communicate and Chat with Users: Twilio
• Data Backup and Security: Mongo Atlas
• Invoice and Billing: Stripe
• Web and Mobile Analytics: Google Analytics, LogRocket
• Website Hosting: Amazon Web Services S3
• Calendar Invites: Google Calendar

We may also share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or some of our business to another company.
• Affiliates: We may share your information with our affiliates, which include our parent company and any subsidiaries, joint venture partners, or other companies we control or that are under common control with us.
• Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.
• Other Users: When you share personal information in public areas of the Services (e.g., comments or contributions), that information may be viewed by all users and may be publicly made available outside the Services in perpetuity.

5. What Is Our Stance on Third-Party Websites?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services but are not affiliated with us.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications.

The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. You should review the policies of such third parties and contact them directly to respond to your questions.

6. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising purposes, including to manage and display advertisements, tailor advertisements to your interests, or send abandoned shopping cart reminders.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics: We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, visit the Google Privacy & Terms page.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information. If this is not possible (for example, because your personal information is stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@paction.ca.

10. What Are Your Privacy Rights?

In Short: In some regions, such as Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right to:

• Request access and obtain a copy of your personal information.
• Request rectification or erasure of your personal information.
• Restrict the processing of your personal information.
• If applicable, request data portability.
• Not be subject to automated decision-making.

In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section "How Can You Contact Us About This Notice?".

Withdrawing Your Consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided in the section "How Can You Contact Us About This Notice?". Please note that this will not affect the lawfulness of the processing before its withdrawal.

Opting Out of Marketing Communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send or by contacting us. You will then be removed from the marketing lists. However, we may still communicate with you for non-marketing purposes, such as service-related messages or account management.

Account Information: If you would like to review or change the information in your account or terminate your account, you can contact us using the details provided. Upon your request, we will deactivate or delete your account and information from our active databases. However, we may retain certain information to prevent fraud, troubleshoot problems, or comply with legal requirements.

11. Controls for Do-Not-Track Features

In Short: Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to be tracked online. However, no uniform standard for recognizing and implementing DNT signals has been finalized.

As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

12. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this notice. If we make material changes to this Privacy Notice, we may notify you by prominently posting a notice of such changes or by directly sending you a notification.

We encourage you to review this Privacy Notice frequently to stay informed about how we are protecting your information.

13. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at privacy@paction.ca or contact us by post at:

14. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we process it, and to correct inaccuracies or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please email us at privacy@paction.ca.