Privacy Policy

At Cold Moose, we respect your privacy and are committed to protecting your personal information. This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

By accessing or using our website, services, or interacting with us, you consent to the collection, use, and disclosure of information as described in this Privacy Policy (subject to any additional consent you may provide).

1. Definitions & Scope

• “Personal information”means information about an identifiable individual (e.g. name, contact information, identifiers) as per PIPEDA.
• “Organization” / “we” / “us”refers to Cold Moose and its affiliates (as applicable).
• “You” / “user” / “customer”refers to an individual or representative of a business interacting with our website or services.
• This Policy governs personal information collected in the course of our commercial activities, including via our website, client onboarding, product orders, service delivery, communications, and other interactions.
• In some jurisdictions, additional or stricter privacy law obligations may apply; this Policy is intended to provide a baseline consistent with Canadian federal privacy law.

2. Accountability

• We designate a Privacy Officer(or equivalent) who is responsible for overseeing our privacy practices, ensuring compliance, and addressing inquiries or complaints about your personal information.
• We will provide training to our employees and contractors who handle personal information to ensure they understand their obligations under this policy and under PIPEDA.
• We will implement internal policies, procedures, and controls to protect personal information and to ensure compliance with this policy.

3. Principles of Collection, Use, and Disclosure

PIPEDA establishes principles for how personal information must be handled. Our practices seek to align with them:

(a) Identifying Purposes

• We will identify the purposes for which we collect personal information at or before the time of collection (or as soon as practicable thereafter).
• We will use or disclose personal information only for those purposes, unless otherwise consented to or permitted by law.

(b) Consent

• We rely on express or implied consent for the collection, use, and disclosure of personal information, except where PIPEDA allows for exceptions.
• You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer (see Contact section).
• Withdrawal of consent may mean we cannot continue providing you with certain services or features.

(c) Limiting Collection

• We will limit the collection of personal information to that which is necessary for the purposes identified.
• Information will be collected by fair and lawful means, with minimal intrusion.

(d) Limiting Use, Disclosure, and Retention

• We will not use or disclose personal information for purposes other than those for which it was collected, except with consent or as required by law.
• We will retain personal information only as long as necessary to fulfill those purposes or as required by law, and will securely destroy or anonymize it when no longer needed.
• We may keep records (e.g. audit logs, transaction histories) as required by legal, regulatory, or business retention policies.

(e) Accuracy

• We will make reasonable efforts to ensure that personal information in our custody is as accurate, complete, and up-to-date as necessary for the identified purposes.
• You may request corrections to your personal information; we will respond in a timely manner.

(f) Safeguards

• We will protect personal information by appropriate security safeguards — physical, organizational, and technological — proportionate to the sensitivity of the information.
• We will monitor and periodically review security measures to ensure they remain appropriate.
• In case of a data breach involving personal information, we will follow applicable breach notification requirements (see Breach section below).

(g) Openness, Transparency

• We will make information about our privacy practices, including this policy, easily available.
• We will provide individuals with access to information about how their personal data is used and disclosed.

(h) Individual Access

• Upon request (and subject to limited exceptions), we will provide you with access to your personal information in our custody or control and information relating to its use or disclosure.
• We may charge a minimal fee for access, consistent with applicable law.
• If you find errors or omissions, you may request correction; if we refuse, we will give reasons.

(i) Challenging Compliance

• Individuals may challenge our compliance with these principles by contacting our Privacy Officer.
• We will investigate all complaints and respond within a reasonable timeframe.
• If we are unable to satisfy your concerns, you may contact the applicable privacy authority (e.g. Office of the Privacy Commissioner of Canada).

4. Types of Information Collected

We may collect, use, and store various types of personal information, including but not limited to:

(a) Identifying & Contact Information

• Name, business name, professional title
• Mailing address, billing address
• Telephone number(s), email address
• Login credentials (username, password)

(b) Transactional / Financial Information

• Payment method information (e.g. credit card number, expiry date, billing address)
• Bank account or financing application information (where applicable)
• Order history, invoices, receipts, payment confirmation
• Tax-related information (as required)

(c) Business / Project Data

• Company profile, industry, size
• Project specifications (e.g. refrigeration requirements, layout, plans)
• Product types, service records, warranty information
• Site or installation location details

(d) Usage, Technical & Analytics Data

• Log files: IP address, browser type and version, operating system, pages visited, times and durations
• Cookies, web beacons, and similar tracking technologies
• Analytics information (e.g. page views, referring sites, conversion metrics)

(e) Identity Verification / Compliance Documents

• In certain cases (e.g. financing, contractual obligations), we may request government-issued ID, business registration documents, or proof of address.

5. How We Use & Disclose Information

We use and disclose information for the following purposes (and similar ones), consistent with the purposes you were informed of:

• To provide, maintain, and support our products, services, installations, and warranties
• To process orders, payments, and financing
• To communicate with you (e.g. confirmations, updates, customer support, promotional offers)
• To respond to inquiries, requests, or complaints
• To enforce our terms, prevent fraud, or protect rights and safety
• To analyze, improve, and personalize our offerings (e.g. site functionality, marketing, product development)
• To comply with legal or regulatory obligations or respond to lawful requests from authorities
• To anonymize or aggregate data for internal reporting or research
• To transfer or assign information in connection with business transactions (e.g. merger, acquisition, sale), provided the recipient agrees to safeguard the information

We will not sell personal information to third parties for their own marketing use without consent.

6. Consent & Withdrawal

• When we first collect personal information, we will seek your consent (express or implied, depending on sensitivity).
• For more sensitive uses (e.g. identity verification, financial data), we will seek express consent.
• You may withdraw consent at any time; we will inform you of the consequences (e.g. inability to serve you certain functionalities).
• We may also ask for renewed consent if we propose to use your information for materially different purposes.

7. Data Retention & Destruction

• We retain personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by law (whichever is longer).
• When no longer required, we securely destroy, erase, or anonymize the data.
• During retention, we isolate or securely store the data to prevent unauthorized access.

8. Security Measures & Breach Handling

• We employ physical, administrative, and technical safeguards (e.g. encryption, access controls, firewalls, secure servers) to protect personal information.
• Our staff and contractors are required to keep information confidential and follow this policy.
• In the event of a breach of security safeguardsinvolving personal information (e.g. unauthorized access, disclosure, or interception) which poses a “real risk of significant harm” to individuals, we will follow PIPEDA’s obligations, including notifying affected individuals and the Privacy Commissioner, unless otherwise exempt under law.
• We will document all breaches and responses and maintain records as required by law.

9. Cross-Border Data Transfers

• Because we operate (or may use third-party service providers) across borders (e.g. cloud providers, analytics, hosting), your personal information may be stored, processed, or transmitted in jurisdictions outside Canada.
• We will take reasonable steps to ensure that foreign jurisdictions provide a comparable level of protection as required under Canadian law (e.g. contractual safeguards, encryption, limiting access).
• You agree to such cross-border transfers by consenting to this policy.

10. Cookies, Tracking & Analytics

• We and our service providers use cookies, web beacons, pixel tags, local storage, and similar technologies to collect usage and technical information.
• These technologies help us (for example):
  Recognize you when you revisit
  • Analyze trends, administer the site, track users’ movements, gather demographic info
  • Provide tailored content, offers, and advertising
• You may control cookies via your browser settings (e.g. block or delete cookies), though doing so may affect site functionality or user experience.

11. Children & Minors

• Our website and services are intended for adults or businesses.
• We do not knowingly collect personal information from minors under the age of majority without consent of a parent or guardian.
• If we learn that personal information of a minor has been collected without appropriate consent, we will promptly delete that information.

12. Third-Party Links & Services

• Our website may include links to third-party websites, services, or applications, which have their own privacy practices.
• This policy does not apply to third parties. We encourage you to review their privacy policies.
• We may also use third-party service providers (e.g. payment processors, analytics providers, cloud hosting) who may collect or process personal information on our behalf. We require these providers to protect data and restrict their use to services for us.

13. Access, Corrections & Complaints

• You may request access to your personal information held by us, subject to limited exceptions (e.g. legal, security).
• You may request corrections or updates; we will respond within a reasonable timeframe.
• If we refuse, we will provide reasons and allow you to annotate your personal information.
• Questions, concerns, or complaints about our practices or compliance should be directed to our Privacy Officer (see Contact section).
• If unresolved, you may lodge a complaint with the Office of the Privacy Commissioner of Canada or other applicable authority.

14. Changes to this Policy

• We may update or revise this Privacy Policy from time to time.
• When changes are material, we will notify users (e.g. via prominent notice, email, or on our website).
• The “Last Updated” date will reflect the most recent update.

15. Contact Information

If you have any questions, requests, or complaints about this Privacy Policy or our handling of personal information, please contact:

Privacy Officer
 Cold Moose
Head office and manifecturing plant | production unit :  41 Ardelt Pl. Unit 2, Kitchener, ON N2C 2C8
+1-519-707-1373
info@coldmoose.ca

You may also contact the Privacy Commissioner of Canada for further guidance or to lodge complaints under PIPEDA.