1. Who we are and scope
Huglers is an independent sole proprietorship based in Ontario, Canada ("Huglers", "we", "us" or "our"). This Privacy Policy applies to personal information handled through huglers.com, direct business inquiries and prospective or active client relationships, unless a separate client privacy or data-processing agreement applies.
Huglers is accountable for personal information under its control. The designated privacy official is the Privacy Officer, Huglers, reachable at hello@huglers.com.
This policy reflects the ten fair information principles in Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"): accountability; identifying purposes; consent; limiting collection; limiting use, disclosure and retention; accuracy; safeguards; openness; individual access; and challenging compliance. Other laws apply where their territorial and subject-matter requirements are met.
2. Personal information we may collect
| Category | Examples | Source and purpose |
|---|---|---|
| Inquiry and contact information | Name, organization, role, email address, phone number, message and attachments | Provided by you through the contact form or email so we can respond and assess a possible engagement. |
| Client and project information | Business contact details, instructions, approvals, project files, correspondence, meeting notes and deliverables | Provided by clients or their authorized representatives to quote, contract, perform and administer services. |
| Transaction and compliance records | Contracts, invoices, payment status, tax information and records needed for accounting or legal compliance | Generated through a business relationship or provided by you. Full payment-card data should be handled by a payment provider, not sent to us by email. |
| Basic technical data | IP address, request date and time, requested page, browser or device information, referring page, and security events | May be processed automatically in short-lived or security logs by the web host, network or server to deliver, secure and diagnose the Website. |
| Consent and preference records | Marketing consent, source, date, status and unsubscribe record | Collected only if marketing communications are introduced, to honour choices and demonstrate compliance. |
We do not intentionally collect sensitive personal information through the Website. Do not email passwords, payment-card numbers, health information, government identifiers, customer banking information or other unnecessary sensitive data.
3. Information not collected by this Website at launch
The Website does not currently:
- create user accounts or profiles;
- accept payments or online orders;
- use an application or newsletter form;
- use advertising, retargeting or behavioural-profiling pixels;
- use analytics scripts;
- use non-essential browser cookies or local storage; or
- sell or rent personal information.
The contact form sends the information you enter to Huglers by email. Hosting and email infrastructure may process that information and basic technical data. If the Website later adds analytics, advertising, accounts, payments or newsletters, this policy will be updated before or when those features launch, and consent controls will be added where required.
4. Purposes and legal grounds
We collect, use and disclose personal information only for purposes a reasonable person would consider appropriate, including to:
- receive, assess and respond to inquiries;
- prepare proposals, verify authority and enter into contracts;
- plan, perform, review and deliver client services;
- communicate about projects, support, security and administration;
- issue invoices, collect amounts owing and maintain tax and accounting records;
- secure, operate, troubleshoot and improve the Website and business systems;
- prevent fraud, misuse, infringement and security incidents;
- establish, exercise or defend legal claims; and
- meet legal, regulatory, insurance and contractual obligations.
Under Canadian privacy law, we generally rely on meaningful consent, which may be express or implied depending on sensitivity and reasonable expectations, or another basis permitted by law. Where the EU or UK GDPR applies, processing may be based on steps requested before a contract, contract performance, legal obligations, consent, or legitimate interests such as responding to business inquiries, securing systems and managing business relationships, balanced against individual rights.
We will identify any new purpose and obtain additional consent before using personal information for a materially unrelated purpose, unless law permits or requires the use without consent.
5. Consent and electronic marketing
Providing personal information voluntarily authorizes us to use it for the stated or reasonably apparent purpose. You may withdraw consent, subject to reasonable notice and legal or contractual restrictions. Withdrawal will not affect prior lawful handling, and it may prevent us from responding or providing a requested service.
Contacting Huglers does not automatically subscribe you to marketing. If we later offer marketing or a newsletter, commercial electronic messages will be sent only where permitted by Canada's Anti-Spam Legislation ("CASL") or other applicable law. Messages will contain required sender identification and a working unsubscribe method. We will retain a minimal suppression record after an opt-out so that we do not send messages against your choice.
6. Disclosure and service providers
We do not sell or rent personal information. We may disclose only what is reasonably necessary to:
- hosting, email, cloud storage, productivity, security, accounting, payment, professional-adviser and technology providers supporting the business;
- client-approved collaborators or subcontractors under appropriate confidentiality and data-protection obligations;
- government, regulators, courts, law enforcement or other parties where required or permitted by law;
- insurers, legal advisers or parties necessary to establish, exercise or defend legal rights; or
- a buyer, successor or adviser in a proposed or completed business transaction, subject to lawful safeguards and permitted use.
Service providers may process information only for authorized purposes. We remain accountable for personal information transferred to a provider for processing where PIPEDA applies and use contractual or other appropriate measures to require a comparable level of protection.
7. International processing
Huglers operates in Canada, but service providers may store or process information in Canada, the United States or other countries. Information in another jurisdiction may be subject to that jurisdiction's laws and lawful access by courts, law enforcement or national-security authorities.
Where applicable law requires a transfer mechanism, assessment or additional safeguards, we will use the required mechanism before the transfer. Depending on the context, this may include contractual protections or another lawful transfer basis under the EU or UK GDPR. Contact the Privacy Officer for information about material service-provider locations or safeguards relevant to your information.
8. Retention and deletion
We retain personal information only as long as reasonably necessary for the identified purposes and applicable legal, accounting, insurance, dispute and contractual requirements. Retention depends on the record and relationship:
- unsuccessful or inactive inquiries are generally removed when no longer useful for follow-up or legal records;
- client project, contract, invoice and tax records may be kept for the period required by Canadian tax law and relevant limitation, insurance or contractual periods;
- security logs are retained for a limited period appropriate to troubleshooting, abuse prevention and incident investigation;
- unsubscribe or suppression records may be kept as long as needed to honour the request and show compliance; and
- backups may retain residual copies until they cycle out under the backup schedule.
When information is no longer required, it is deleted, anonymized or securely destroyed. We may retain information where law requires it or where reasonably necessary for an active legal claim.
9. Safeguards and incidents
We use administrative, technical and physical safeguards appropriate to the sensitivity, amount, format and risk of the information. Measures may include access controls, strong authentication, software updates, reputable service providers, encryption in transit where supported, backups, confidentiality obligations and limiting collection.
No internet transmission, email or storage system is perfectly secure. We cannot guarantee absolute security. If a breach of security safeguards occurs, we will investigate and take reasonable containment and remediation steps. Where PIPEDA applies, we will keep required breach records and report to the Office of the Privacy Commissioner of Canada and notify affected individuals when the breach creates a real risk of significant harm. We will also meet other applicable notification requirements.
10. Accuracy, access and correction
You may ask whether we hold personal information about you and request access to it or correction of inaccurate or incomplete information. Send a written request to the Privacy Officer with enough detail to identify the relevant records. We may verify identity before responding.
We will respond within the period required by applicable law and at little or no cost, subject to lawful exceptions. We may refuse or limit access where permitted or required, including where disclosure would reveal another person's personal information, confidential commercial information, privileged material or information that cannot lawfully be disclosed. If we refuse, we will explain the reason where permitted and identify available recourse.
11. Additional rights in some jurisdictions
Depending on where you live and whether the relevant law applies to Huglers, you may also have rights to request deletion, restrict or object to processing, receive portable data, withdraw consent, or complain to a privacy regulator. EU and UK residents may have these rights under the GDPR or UK GDPR where the applicable law's territorial scope is met.
Huglers does not currently sell or share personal information for cross-context behavioural advertising. If a law such as the California Consumer Privacy Act applies to Huglers in the future, we will provide the notices and rights required at that time. This paragraph does not claim that every foreign privacy law currently applies to Huglers.
We will not discriminate against anyone for exercising a privacy right. Rights are subject to verification, exceptions and territorial thresholds under the relevant law.
12. Automated decisions and artificial intelligence
Huglers may use AI-assisted tools for drafting, research, organization, coding or creative work. We do not use the Website to make solely automated decisions that produce legal or similarly significant effects about visitors.
Client or personal information will not be intentionally submitted to a public AI tool unless authorized, appropriately protected, or permitted by the applicable Service Agreement and law. Where an AI provider processes personal information for an authorized business purpose, it is treated as a service provider and assessed according to sensitivity and risk.
13. Third-party links
The Website may link to independent third parties. Their privacy policies and practices govern information they collect. Huglers is not responsible for third-party handling of personal information, and a link is not an endorsement. Review the destination's policy before providing information.
14. Children
The Website and services are intended for adults and business users. We do not knowingly collect personal information from children through the Website. If you believe a child provided personal information, contact the Privacy Officer so we can assess and delete it where appropriate.
15. Complaints
Send privacy questions or complaints to the Privacy Officer. We will acknowledge and investigate a complaint, explain our findings and take appropriate corrective action where warranted.
If you are not satisfied, you may contact the Office of the Privacy Commissioner of Canada. Residents of another jurisdiction may also have the right to complain to their local supervisory authority where that authority and law have jurisdiction.
16. Policy changes
We may update this policy when our practices, services, providers or legal obligations change. The current version will be posted here with a revised date. If a change is material, we will provide additional notice or request consent where required by law. We will not use previously collected information for a materially new purpose without appropriate notice and consent or another lawful basis.
17. Contact the Privacy Officer
Privacy Officer, Huglers
PO Box 30015
Milton, ON, L9T0L8
hello@huglers.com
Use the subject line "Privacy Request". Please do not include sensitive identity documents in your first email. We will explain any secure verification needed.