OrderGrid Inc. Privacy Notice

Last update: October 1, 2024

1. OUR APPROACH TO PRIVACY
   1. OrderGrid Inc. ("OrderGrid", "we", "our", or "us") is committed to protecting and respecting your privacy. This privacy notice sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal data") when you access and browse our website ("Website"), use our services or purchase products from us (together, the "Service"). This notice also includes information regarding our use of cookies and similar technologies, and outlines the rights granted to you under applicable global privacy laws. 
   2. This privacy notice is designed to comply with various global data protection and privacy laws, including but not limited to:

• The General Data Protection Regulation (GDPR) in the European Union (EU) and the United Kingdom (UK)
• The California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) in the United States (US)
• The Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada
• UAE Data Protection Laws (such as DIFC Data Protection Law)
• The Personal Data (Privacy) Ordinance (PDPO) in Hong Kong

If you have any questions about this privacy notice or how we use your personal data, please contact us using the details at the end of this privacy notice.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

1. OrderGrid is the data controller of the personal data we hold about you. This means that we determine and are responsible for how your personal data is used, in compliance with the relevant legal frameworks. 
2. Depending on your location, we may also be considered a "data processor" when processing personal data on behalf of other businesses. In such cases, our customers may be the data controllers, and they have their own privacy policies. We do not accept responsibility for their policies, so please check these individual policies before submitting personal data to them.
3. PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE USE IT
   1. We collect personal data that you voluntarily submit directly to us when you use the OrderGrid Service. This can include information you provide to us when you make a request on our Website, purchase our products, correspond with us by phone, e-mail or otherwise, subscribe for our marketing communications, or use some other feature of our Service. 
   2. This information may include, for example, your contact details such as your name and email address. We will indicate to you if the provision of certain personal data is mandatory or optional. If you choose not to provide any personal data marked as mandatory, we may not be able to respond to your queries or provide other services to you or respond to your other requests.
   3. The table at Annex 1 sets out in detail the categories of personal data we collect about you and how we use that information when you use the Service, as well as the legal basis which we rely on to process the personal data and recipients of that personal data.
   4. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY
   5. We also automatically collect personal data indirectly about how you access and use the Website, and information about the device you use to access the Website, read our emails, or otherwise engage with the Service. We use this information to provide to you the features and functionality of the Service, to monitor and improve the Service and to develop new products and services. We typically collect this information through a variety of tracking technologies, including cookies and similar tracking technologies.
   6. The table at Annex 2 sets out in detail the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data and recipients of that personal data. For more information on cookies and other tracking technologies we use, please see Section 8 below.
   7. We may link or combine the personal data we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
   8. We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Website and our services or developing new services and features. We may also share such anonymized and aggregated information with others.
4. HOW LONG WE KEEP YOUR PERSONAL DATA
   1. We will store the personal data we collect for our own purposes for no longer than necessary for the purposes set out in this privacy notice and in accordance with our legal obligations and legitimate business interests.
   2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
5. RECIPIENTS
   1. As required in accordance with how we use your personal data, we may share your personal data with the following: some text
      1. Service providers and advisors. We may share your personal data with third party vendors and other service providers that perform services for us or on our behalf, which may include warehouse services providers, e-commerce providers, payment card processors, carriers, shipping providers, telephone and technical support providers, hosting, data storage and processing service providers, legal and accounting service providers and research and analytics providers. 
      2. Purchasers and third parties in connection with a business transaction. Your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
      3. Law enforcement, regulators and other parties for legal reasons. We may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of OrderGrid, its users or others.
      4. Affiliates. We may share your personal data with affiliated legal entities within our family of companies for purposes and uses that are consistent with this privacy notice, such as for the provision of our services and Website.
6. MARKETING
   1. From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
   2. Our marketing messages will be sent by email, text, and post. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.
   3. We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails, by opting out via the link in the text message, or, if you created an online account when you registered to receive our emails, you may log-in to your account and make changes to your communication preferences. You may also opt-out by contacting us directly using the contact information in the "Contacting Us" section below. We make every effort to process all unsubscribe requests promptly. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
7. COOKIES AND SIMILAR TECHNOLOGIES
   1. The Website uses cookies and similar tracking technologies to distinguish you from other users of the Website. Cookies are pieces of code that we transfer to your device for record-keeping purposes. This helps us to provide certain functionalities of the Website, to monitor and improve the Website, as well as to allow our partners determine products and services that may be of interest to you and to display relevant advertising to you as you browse the Internet.
   2. We use the following types of cookies:
      1. Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
      2. Analytical/performance cookies. They allow us to recognise and count the number of visitors, to see how visitors move around the Website when they are using it and to monitor the performance of certain features on the Website. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily and to test the rollout of new features.
      3. Functionality cookies. These are used to recognise you as you move around the Website and to remember information that you enter when you use the Website, such as when you fill in a form.
      4. Targeting cookies. These are used to record your visit to our Website, the pages you have visited and the links you have followed. They allow us to obtain an understanding of your interests and to deliver relevant adverts that you may be interested in.
      5. Third party cookies. Please be aware that advertisers and other third parties may use their own cookies or tracking technologies when you click on an advertisement or link on our Website. These third parties are responsible for setting out their own cookie and privacy policies.
   3. Annex 3 contains more information about the cookies we use and how long they remain on your device. 
   4. Other than cookies that are required to operate the Website, we will only place cookies on your device with your consent. You can also change your preferences in relation to the cookies you consent to receive by accessing our cookie banner on our website. 
   5. You also have the ability to opt out by disabling cookies in your browser or mobile settings. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.
      1. Cookie settings in Internet Explorer
      2. Cookie settings in Firefox
      3. Cookie settings in Chrome
      4. Cookie settings in Safari web and iOS.
8. STORING AND TRANSFERRING YOUR PERSONAL DATA
   1. Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
   2. International Transfers of your personal data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the UK or European Economic Area ("EEA"), your personal data may be processed outside of the UK or EEA. These international transfers of your personal data will be made pursuant to appropriate safeguards, including:
      1. ensuring that the personal data is transferred to countries recognised by the European Commission or the UK Secretary of State (as applicable) as offering an equivalent level of protection; or
      2. ensuring that such transfer is to a third party who uses appropriate safeguards in respect of the processing in question, including but not limited to the UK or EU standard contractual clauses, which are recognised as offering adequate protection for the rights and freedoms of data subjects, as determined by the European Commission or the UK Secretary of State (as applicable). 
   3. We will take appropriate steps to ensure that your personal data is treated securely and in accordance with applicable law and this privacy notice regardless of where it is processed.
   4. If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy notice. 
9. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
   1. In accordance with applicable privacy laws, you have the following rights in respect of your personal data that we hold:
      1. Right of access. You have the right to obtain:
         1. confirmation of whether, and where, we are processing your personal data;
         2. information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
         3. information about the categories of recipients with whom we may share your personal data; and
         4. a copy of the personal data we hold about you.
      2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
      3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay. 
      4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified. 
      5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
   2. You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal data despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. 
   3. If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy notice. 
   4. We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs. 
   5. You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK, information about how to contact your local data protection authority is available here.

10. California Consumer Privacy Act (CCPA)

1. At OrderGrid, we operate as a business-to-business ("B2B") service provider and software company. We do not intentionally interact with or collect personal information about individual consumers outside of this context, whether through our platforms or offline interactions. Any references to "you" in this privacy notice pertain solely to individuals engaging with us in a B2B capacity. Only individuals acting in a B2B role are permitted to use our websites or provide personal information to us.
2. As outlined in the "With Whom We Share Personal Information" section above, we may share your personal information with third parties for specific purposes related to providing our services. However, OrderGrid does not "sell" personal information as defined under the CCPA.
3. The CCPA grants California residents certain rights, including:

• The right to access specific categories of personal information we collect.
• The right to know how we process personal information.
• The right to request the deletion of your personal information.
• The right not to be denied goods or services for exercising these rights.

1. For more information about how to exercise your rights, please refer to the "Contacting Us" section below.
2. California Shine the Light Law: California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please contact us using the information in the “Contacting Us” section below.

11. LINKS TO THIRD PARTY SITES

The Website may, from time to time, contain links to and from third party websites, including those of our partners, advertisers, news publications, social media platforms and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

12. OUR POLICY TOWARDS CHILDREN

The Website is not directed at persons under 16 and we do not knowingly collect personal data from children under 16. If you become aware that your child has provided us with personal data, without your consent, then please contact us using the details below so that we can take steps to remove such information as quickly as possible.

13. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time and so you should review this page periodically. When we change this privacy notice in a material way, we will update the "last modified" date at the end of this privacy notice. Changes to this privacy notice are effective when they are posted on this page.

14. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Website.  

15. CONTACTING US

1. Please contact the following if you have any questions, comments and requests regarding this privacy notice:
   1. Email: privacy@ordergrid.com; and 
   2. Address: FAO The Privacy Officer, OrderGrid Inc. 780 Tapscott Road, Unit 5 Scarborough, ON M1X 1A3 Canada. 

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