Privacy Policy

Privacy Statement

Last Updated: August 2026

PrivacyWorks Consulting Inc. (also referred to as “PrivacyWorks”, “us”, “we”) values your privacy rights. We are committed to managing your personal information in a responsible and transparent manner.

This Privacy Statement describes how we process and manage your personal information. It also describes your rights and our responsibilities.

What is personal information?

Personal information includes any information relating to an identifiable information. This includes information that can directly identify an individual, such as their full name. This also includes information that can be used to identify an individual when combined with other information, such as location data or IP addresses.

What activities does this statement apply to?

This Privacy Statement applies to our collection, access, use, storage, transfer, retention and protection (collectively referred to as “management”) of your personal information relating to:

·       Your use of our website (including webpages under the domains: privacyworks.ca, privacyworks-consulting-inc.breezy.hr, and privacyworks.talentlms.com).

·       Our delivery of products and services to you or our clients;

·       Your communications with us by any means (including by phone, online or through email);

·       Your application for employment and/or employment with us; and,

·       Any other activities related to our operations.

We may provide you with more specific privacy statements or notices. This Privacy Statement should be read in combination with any other privacy statements or notices we provide you.

Personal information that we manage on behalf of our clients may also be subject to additional contractual requirements or restrictions.

Where do we operate?

We are headquartered out of Vancouver, British Columbia, but operate globally. We may manage personal information of residents of multiple countries in the course of our operations.

We have developed a harmonized privacy management program to ensure compliance with all privacy laws applicable to our operations.

What are our responsibilities?

PrivacyWorks is accountable for managing the personal information we hold in accordance with applicable privacy laws.

In general, we must:

·       Limit the collection, use and disclosure of your personal information to what is reasonably necessary for lawfully authorized purposes.

·       Obtain your consent to collect, use and disclose your personal information, unless we’re authorized or required by law to do so without your consent.

·       Take all reasonable steps to protect the personal information we manage.

·       Only keep your personal information as long as necessary to fulfill the purposes we collected it for, or as required by law.

·       Take all reasonable steps to ensure the personal information we manage is accurate and complete.

·       Inform you of how we manage your personal information.

·       Assist you in exercising your privacy rights.

·       Respond to your requests, inquiries and complaints fully and in a timely manner.

Our website may include links to other third-party websites. We are not responsible for the information practices of these third parties, and our Privacy Statement does not govern these websites. We encourage you to review the privacy statements of any third-party website you visit.

Why do we collect, use and disclose your personal information?

We may collect, use and disclose your personal information when it is reasonably necessary to:

·       Deliver, evaluate and improve our products and services.

·       Market and advertise of products and services.

·       Process payments for our products and services.

·       Respond to, or send you, communications (such as through a newsletter if you choose to subscribe).

·       Recruit new employees, and to establish and maintain employment or contractual relationships.

·       Ensure the security of our information and information systems.

·       Comply with applicable laws and regulations (or as otherwise authorized by law).

If we collect, use or disclose your personal information for other purposes, we will obtain your consent before doing so.

How do we collect your personal information?

We often collect your personal information directly from you. For example, we collect your personal information when you:

·       Contact us directly through our website, social media platforms, LinkedIn, email, or phone.

·       Visit our website (see “Do we use cookies or other tracking technologies” below for more information).

·       Submit a job application to work with PrivacyWorks.

·       Purchase or register for a product or service, such as when you register for a training course.

·       Provide feedback or opinions about our products and services.

We may also indirectly collect your personal information from another source. For example, we collect your personal information indirectly when:

·       It is reasonably necessary to obtain your personal information from our clients to deliver services to our client under contract (such as when we manage privacy breaches or process access to information requests on behalf of our clients).

·       We contact your employment references, with your consent, to perform reference checks during the hiring process.

When we collect personal information on behalf of our clients, we collect that personal information in accordance with the instructions of our clients and applicable privacy laws.

What personal information do we collect?

We limit the amount of personal information we collect to what is reasonably necessary and appropriate, based on the purpose we collect it for.

Examples of personal information we collect include:

·       Your name, contact information, and the nature of your question or concern when you communicate with us directly.

·       Your web browsing activity and device information when you visit our website (see “Do we use cookies or other tracking technologies” below for more information).

·       Data respecting your registration, purchase and/or use of our products and services. This may include sensitive personal information, such as financial information required for payment processing or health information collected to ensure we can meet your accessibility needs when attending our events, if applicable.

·       Your name, email address, eLearning completion status, eLearning quiz results, and certificate of completion when you complete one of PrivacyWorks’ eLearning modules.

·       Your name, email address, resume, and other information you choose to provide when submitting a job application.

·       Any personal information within records we reasonably need to manage in order to deliver our products and services on behalf of our clients. For example, if you submit a request for access to information held by one of our clients who has contracted us to process access to information requests on their behalf, we may collect any personal information within the records responsive in order to assist our client in responding to your request.

Do we collect personal information of children?

Our website is not intended for use by children under the age of 14. We do not knowingly manage the personal information of children via our website.

We may manage personal information of children in limited circumstances, with appropriate lawful authority, such as:

·       When doing so is reasonably necessary to perform a lawfully authorized activity (such as managing a privacy breach) on behalf of our clients, under contract.

·       To provide extended benefits to children of our employees.

How do we use your personal information?

We may use your personal information for the purpose we collected it, or for a consistent purpose. When we use personal information on behalf of our clients, we use that personal information in accordance with the instructions of our clients and applicable laws.

We will only use your personal information for another purpose with your consent, or where authorized or required by law.

We generally do not use your personal information in an automated system to make a recommendation or decision that directly affects you. If we intend to use your personal information in an automated system at the time we collect it, we will inform you of this intention.

Do we use cookies or other tracking technologies?

Yes. PrivacyWorks uses cookies and other tracking technologies, such as pixels.

Cookies and pixels are digital tracking tools used to monitor user behaviour, remember preferences and deliver targeted advertisements and marketing campaigns.

We may use various categories of cookies and pixels across our digital environments, such as:

·       Essential Cookies: These cookies enable the core functionality of our website and support activities relating to (for example) website security, identity verification and network management.

·       Marketing Cookies: These cookies are used to track advertising effectiveness to provide a more relevant service and deliver better ads to suit your interests.

·       Functional Cookies: These cookies collect data to remember preferences or choices our website visitors make to provide for a more personalized experience.

·       Analytics Cookies: These cookies help us to understand how our website visitors interact with our website, products and services, and provide for broader analytics to support in the maintenance and improvement of our website.

·       Website Pixels: These pixels collect data to enhance our ability to track user behaviour and built targeting audiences for marketing and advertising purposes.

·       Email Pixels: These pixels collect data to help our understand how you interact with our communications to you, such as newsletters or marketing communications.

You can opt-out of or disable the use of cookies and pixels through your browser and email settings. If you choose to do this, please be aware that the functionality of our website may be affected.

Who do we disclose or share personal information to / with?

We do not sell, rent, license or trade your personal information for any purpose.

We may disclose your personal information to, or share your personal information with, our clients when reasonably necessary for the purposes of delivering contracted services to our clients.

We may also disclose your personal information to, or share your personal information with, third-party service providers we engage to deliver services on our behalf. This includes, for example, cloud-services providers such as Microsoft and advertising solution providers such as Google.

We remain accountable for personal information managed by third-party service providers on our behalf, and we take reasonable steps to ensure our third-party service providers uphold all applicable privacy rights and responsibilities.

We will only disclose or share your personal information for other purposes with your consent, or if otherwise authorized or required by law.

How do we obtain your consent to manage personal information?

When required, we obtain your consent to collect, use and disclose your personal information in accordance with applicable laws.

This may include, for example:

·       Express or explicit consent: We obtain express or explicit consent when we request your clear and unambiguous agreement. This requires you taking an affirmative action, such as signing a consent form or clicking “I Agree” at the bottom of a privacy notice.

·       Implied or implicit consent: We obtain implied consent when we it is reasonable to infer that you agree to the collection, use or disclosure of your personal information. This may occur, for example, when you contact us with an inquiry and we collect the personal information you voluntarily provide to us and use that personal information to respond to your inquiry.

·       Consent by not opting out: In limited cases, we may obtain consent by not opting out, which occurs when we (1) inform you of the purposes for collecting, using and disclosing your personal information, (2) give you a reasonable opportunity to opt out or decline, and (3) you choose not to opt out or decline. A common example of this consent type is a privacy notice followed by a check box indicating “Check this box to opt out of X activity”.

Where do we store your personal information?

We aim to store and process all personal information from within Canada, including all back ups of personal information. This includes personal information stored or processed by our third-party service providers on our behalf.

However, unless we are subject to a legal, regulatory or contractual requirement to store and process personal information in Canada, we may store and process personal information outside of Canada. In such cases, your personal information may be subject to the laws of the jurisdiction(s) in which we store and process personal information.

If we intend to store or process personal information outside of Canada at the time of collecting your personal information directly from you, we will inform you of this intent.

For our clients located or operating outside of Canada, we strive to comply with applicable data residency requirements. This may include, for example, ensuring appropriate lawful authority for third party data disclosures and/or configuring solutions to store and process personal information for those clients within the required jurisdiction(s).

How long do we keep your personal information?

We maintain a records retention and disposition schedule to specify the retention period for each category of personal information records we hold. In general, our records retention and disposition schedule requires us to keep personal information for the longest of the period:

·       Required to fulfil the purposes for which we collect or use the personal information, including our legitimate business interests.

·       Specified by legal, professional or contractual requirements.

·       During which the personal information is subject to a litigation hold.

·       Necessary to enable you to fully exhaust any appeal rights you may have after executing your privacy rights.

When we use personal information to make a decision that directly affects an individual, we retain the personal information for the minimum period specified under the applicable privacy law(s).

How do we protect your personal information?

We take all reasonable steps to protect the personal information we manage. This includes physical, technical and organizational measures to ensure the confidentiality, availability, accuracy and integrity of your personal information. This includes, for example:

·       Technical Measures, such as firewalls, multi-factor authentication, encryption, intrusion detection and prevention technologies and anti-virus software.

·       Organizational Measures, such as defined governance structures, documented policies and procedures, comprehensive privacy and security assessments, role-based access controls, employee confidentiality agreements and ongoing training.

·       Physical Measures, such as restrictions to physical locations where personal information or information systems are stored, CCTV surveillance and physical and environmental controls for data centres.

·       Accuracy Measures, such as collecting personal information directly whenever reasonably possible, configuring form field response and validation rules and cross validating personal information when appropriate.

As previously stated, we also require our third-party service providers to take commensurate steps to protect the personal information they manage on our behalf. This includes, but is not limited to, entering into contractual agreements (e.g., including data sharing agreements) with our third-party service providers to bind them to these obligations.

It is important to note that while we take all reasonable steps to protect personal information we manage, we can not provide an absolute guarantee of security for all personal information transferred to or by us. Please be aware that the use of standard email is insecure, and choosing to communicate with us via standard email may introduce additional risks to the security of your personal information communicated via email.

What are your privacy rights?

Your rights may vary based on where you reside and the applicable privacy laws. However, you generally have the right to:

·       Obtain information about how we manage your personal information, including when we use automated systems or store or process your personal information outside of your jurisdiction.

·       Make decisions about how we manage your personal information.

·       Give, withhold or withdraw your consent to our collection, use or disclosure of your personal information (if we rely on your consent for these purposes).

·       Request access to, or correction of, your own personal information.

·       Request the transfer of your personal information to another party.

·       Request the erasure of your personal information.

·       Ask us questions, and receive timely and complete responses to your questions, respecting this Privacy Statement and our information practices.

·       Challenge our compliance with this Privacy Statement and/or submit a complaint to us respecting our information practices.

·       Submit a complaint and/or request for review to a supervisory authority, such as the Office of the Information and Privacy Commissioner for British Columbia (see “Who can you contact with questions or concerns” for more information).

Note that your ability to exercise these rights may be partially limited by applicable privacy law. If we refuse to allow you to exercise any of the above rights, we will inform you of the legal basis for our refusal.

How can you exercise your privacy rights?

To exercise your privacy rights, please contact our Chief Privacy Officer:

Name:           Adam Stinson

Title:              Chief Executive Officer and Chief Privacy Officer

Email:           Privacy@privacyworks.ca

Phone:         1–800–983–0776

Who can you contact with questions or concerns?

Contact our Chief Privacy Officer with any questions or concerns about this Privacy Statement or our information practices. Refer to “How can you exercise your privacy rights?” above for the contact information.

You may also have the right to submit a complaint to a supervisory authority. The Office of the Privacy Commissioner of Canada has published an interactive digital tool to help Canadians identify which regulator to contact with their privacy concerns. This digital tool is available at: https://www.priv.gc.ca/en/report-a-concern/leg_info_201405/.

You may also have the right to submit a complaint to another supervisory authority, such as a data protection supervisory authority in an EU member state if you are an EU resident.

You may contact our Chief Privacy Officer at any time for guidance on which supervisory authority would be most appropriate to direct your privacy concern to. When responding to any privacy concerns or complaints, we will provide this information proactively whenever reasonably possible.

Do we update this privacy statement?

We will occasionally update this Privacy Statement to reflect changes to our information practices and services. We will also update this Privacy Statement if there are changes to applicable privacy laws.

We will post any changes to this page and will revise the “last updated” date specified at the beginning of this Privacy Statement. If the changes are significant, we will provide a more prominent notice on our website. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to periodically review this Privacy Statement for the latest information.