Privacy Policy

TWC is the controller responsible for the Personal Information processed through the Platform, except where this Policy or applicable law designates another party. TWC operates a business-to-business matchmaking service for Canadian organizations.

This Policy applies to all users of the Platform, including business representatives, account holders, and visitors. It does not apply to third-party websites, products, or services that we do not control, even where they link to or from the Platform.

The Platform is intended solely for business and professional use by organizations and the individuals authorized to act on their behalf. It is not directed to, or intended for, personal, household, or consumer use.

By accessing, browsing, registering for, or using the Platform, you confirm that you have read and understood this Policy and agree to the processing of Personal Information as described. If you do not agree, you must not access or use the Platform.

This Policy, together with the Terms of Use, is the complete statement of how we handle Personal Information on the Platform. You should not rely on any statement, representation, or understanding about our privacy practices that is not set out in this Policy or required by applicable law.

This Policy forms part of, and should be read together with, the TWC Terms of Use and any product-specific terms. Where a separate written agreement signed by an authorized representative of TWC applies, that agreement governs to the extent of any conflict.

In Canada, TWC handles Personal Information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws, including Quebec's Law 25. Where you are located outside Canada, additional or different laws may apply, as described in Sections 19 through 21.

Name, business email address, business phone number, job title, organization, and similar contact details you provide when registering or communicating with us.

Information you submit to build and operate your business profile, including descriptions, categories, capabilities, locations, documents, and other content you choose to provide.

Messages, prompts, feedback, support requests, and other content you submit through the Platform, including interactions with TINA and other features.

Plan, subscription, token balance, and billing-related information. Payment-card details are processed by our payment providers and are not stored by TWC.

Device, browser, IP address, identifiers, log data, and usage information generated when you access the Platform.

Records of access, authentication, and activity used to operate, secure, and audit the Platform.

Information collected through cookies and similar technologies, as described in Section 13.

Where you submit information about other individuals (for example, colleagues or contacts), you represent that you are authorized to do so and that the information may be processed under this Policy.

We do not seek, and ask that you not submit, sensitive Personal Information. Where we collect it, we use it only as reasonably necessary to provide the Services or as permitted by law.

Matches, recommendations, and Connections are generated from profile data and are provided for your convenience and consideration only. They reflect data patterns, not professional judgment about any organization.

TWC does not independently investigate, verify, vet, endorse, or guarantee any user, organization, profile, statement, capability, or Connection surfaced by the Platform.

You are solely responsible for conducting your own due diligence before contacting, contracting with, or relying on any Connection. You should independently confirm the identity, suitability, qualifications, and standing of any party.

The Insight Engine analyzes information you and others provide to generate insights about your profile and potential opportunities. It does not make decisions on your behalf.

Insight Engine output consists of automated suggestions for your consideration. It is not professional, legal, financial, or business advice, and must not be relied upon as such.

Output may be incomplete, inaccurate, or unsuitable for your circumstances. You are responsible for evaluating it and exercising your own judgment before acting.

TWC does not warrant that any insight, suggestion, or opportunity will result in a Connection, transaction, or business outcome.

TINA is an optional convenience feature. It is not a professional, advisor, agent, or representative of TWC, and using it creates no advisory or fiduciary relationship.

TINA is intended for business and professional purposes connected to your use of the Platform. Do not use it for personal, consumer, or high-risk purposes.

TINA does not provide legal, financial, tax, accounting, medical, or other professional advice. Always obtain advice from a qualified professional before acting.

TINA's responses are machine-generated and may be inaccurate, incomplete, or unsuitable. You are responsible for verifying output and for any decision based on it.

The Platform does not make decisions that produce legal or similarly significant effects about you without human involvement. Automated output is informational and supports (but does not replace) your own decisions.

We process profile and usage data to generate matches, recommendations, and insights. This involves analyzing business information to identify potential opportunities.

Some features rely on generative technology and third-party models. Output is probabilistic and may be inaccurate. It is provided “as is” for your consideration.

Automated systems may produce errors, omissions, or biased results, and may not reflect current facts or circumstances. You should not rely on them as a sole basis for decisions.

Where features rely on third-party providers, their availability, performance, and changes are outside our control, and TWC is not responsible for them.

Outbound communications facilitated by the Platform are business communications between organizations. TWC provides tools, not the content of your messages.

You are responsible for ensuring your communications comply with applicable anti-spam, marketing, and privacy laws, including obtaining any required consents.

Where you submit or use third-party contact information, you represent that you are authorized to do so, and you are responsible for your use of it.

TWC does not verify recipients or the appropriateness of your communications and is not responsible for them.

Facilitating a communication is not an endorsement by TWC of any party, message, or transaction.

Where permitted, we may send you marketing communications about the Platform and related services. We rely on consent or another lawful basis as applicable.

You can opt out of marketing communications at any time using the unsubscribe link or by contacting us. Service and transactional messages will continue.

Where offered and where you opt in, we may send text messages. Message and data rates may apply, and you can opt out by following the instructions provided.

Business profile information is shared with other users to enable matching and Connections, consistent with the purpose of the Platform.

We share information with vendors who process it on our behalf under contractual safeguards, such as hosting, analytics, communications, and support providers.

Certain features transmit content to third-party technology providers to generate output. We use providers under terms that restrict use to providing the service to us, where reasonably available.

We may disclose information to comply with law, respond to lawful requests, enforce our terms, or protect the rights, safety, and property of TWC, users, or others.

We may disclose information in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate protections.

We share information as you direct or where you otherwise consent.

We may share aggregated or de-identified information that does not identify you, as permitted by law.

We use strictly necessary, functional, analytics, and (where permitted) marketing cookies and similar technologies to operate and improve the Platform.

Where required, we obtain consent for non-essential cookies. Strictly necessary cookies do not require consent.

You can manage cookies through your browser settings and, where available, our cookie controls. Disabling some cookies may affect Platform functionality.

Personal Information may be processed and stored in Canada and in other countries where we or our service providers operate.

Where information is transferred across borders, we use appropriate safeguards as required by applicable law, such as contractual protections.

Information processed in another jurisdiction may be subject to the laws of that jurisdiction, including lawful access by courts and authorities.

We rely on recognized transfer mechanisms where required, and make further information available on request.

We retain Personal Information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements.

Retention periods depend on the nature of the information, the purpose of processing, and applicable legal, accounting, and security requirements.

When information is no longer required, we delete, anonymize, or de-identify it in accordance with our policies and applicable law.

We maintain administrative, technical, and physical safeguards designed to protect Personal Information appropriate to its sensitivity.

You are responsible for safeguarding your credentials and for activity under your account. Notify us promptly of any suspected unauthorized access.

Security is a shared responsibility. You should use strong credentials, keep your systems secure, and follow good security practices.

We maintain procedures to detect, assess, and respond to security and confidentiality incidents involving Personal Information.

Where required by law, we will notify affected individuals and relevant authorities of a reportable incident within the timeframes required.

We maintain records of confidentiality incidents as required by applicable law.

We will cooperate with authorities and take reasonable steps to mitigate the effects of an incident.

We comply with applicable breach-notification obligations in the jurisdictions where we operate.

Nothing in this Section limits the disclaimers, limitations of liability, exclusions, or indemnities in the Terms of Use, which apply with full force to any claim arising out of or relating to a security incident, to the maximum extent permitted by law.

Subject to applicable law, you may have the right to access, correct, delete, restrict, or object to processing, to data portability, and to withdraw consent.

Submit a request by email to privacy@tradewithcanadians.ca with the subject line “Privacy Rights Request” and a clear description of your request.

To protect your information, we will take reasonable steps to verify your identity before fulfilling a request. We may decline a request where we cannot verify identity to the level required by law.

We respond within the timeframes required by applicable law, subject to lawful extensions, and will inform you of any extension and the reasons for it.

Requests are generally free of charge. We may charge a reasonable fee, or decline, where a request is manifestly unfounded, excessive, or repetitive, to the extent permitted by law.

If we deny a request, we will explain the reasons where required and inform you how to appeal or escalate, including to a competent regulator.

Rights are subject to exceptions under applicable law, for example, where a request would adversely affect the rights of others, reveal confidential information, or is subject to legal privilege or legal hold.

We collect and use the categories of Personal Information described in this Policy for the business purposes described herein. We have not “sold” Personal Information for monetary consideration.

We do not use or disclose sensitive Personal Information for purposes that require an opt-out under the CPRA, beyond what is reasonably necessary to provide the Services.

California residents may have rights to know, access, delete, correct, and to limit the use and disclosure of sensitive Personal Information, subject to exceptions and verification.

Residents of other U.S. states with comprehensive privacy laws may have comparable rights. We honour applicable opt-out preference signals where required by applicable law.

California residents may request information regarding certain disclosures of Personal Information for third-party direct-marketing purposes. We do not disclose Personal Information for such purposes.

If you are in the EEA, UK, or Switzerland, you have the rights described in Section 18, including access, rectification, erasure, restriction, portability, and objection, subject to applicable exceptions.

Where we process Personal Information on the basis of legitimate interests, we have balanced those interests against your rights and freedoms. You may request further information about that balancing.

Where required, individuals may direct enquiries to privacy@tradewithcanadians.ca, and we will route them appropriately.

You have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or place of the alleged infringement.

TWC has designated a person responsible for the protection of Personal Information, who can be contacted at privacy@tradewithcanadians.ca (Attention: Privacy Officer).

Where required by Quebec Law 25, we conduct privacy-impact assessments before transferring Personal Information outside Quebec or undertaking certain projects.

Quebec residents may have the right to be informed of and access Personal Information held about them, to request information about automated decisions, and to lodge a complaint with the CAI.

TWC maintains a register of confidentiality incidents as required by Quebec Law 25.