Privacy Policy

1. Introduction

THR Guidance Inc., doing business as THR Guidance, is a Canadian computer systems design and integration company headquartered at 71 Stockell Cres, Ajax, Ontario L1T 0M4, Canada. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website located at www.thrguidance.mom, use our services, or otherwise interact with us.

We are committed to protecting your privacy and handling your personal information in accordance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act, as well as other provincial and territorial privacy laws that may apply to our operations. By accessing or using our website and services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Voluntarily

We collect personal information that you voluntarily provide to us when you fill out contact forms on our website, send us email inquiries at service@thrguidance.mom, call our office at +1 (754) 777-4920, subscribe to our newsletters, request a consultation or service quote, or otherwise communicate with us. The types of personal information we may collect include:

• Full name and job title
• Company or organization name and industry classification
• Email address and telephone number
• Physical address, including street address, city, province or state, and postal or ZIP code
• Details about your business requirements, technology infrastructure, and system integration needs
• Any other information you choose to provide in your communications with us
• Billing and payment information when you engage our services

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain information about your device and browsing activity through standard web technologies. This may include:

• Internet Protocol address and approximate geographic location derived from your IP address
• Browser type and version, operating system, and device type
• Pages visited on our website, date and time of access, and time spent on each page
• Referring website or search engine that directed you to our site
• Clickstream data showing your navigation path through our website
• Screen resolution, language preferences, and other technical browser-level data

This automatically collected information is used for website analytics, security monitoring, and improving the performance and user experience of our online services. It is typically aggregated and does not directly identify you as an individual, except where combined with other data we hold.

2.3 Cookies and Similar Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and collect analytics data. Cookies are small text files stored on your device by your web browser. We use the following categories of cookies:

• Essential Cookies: Required for the basic functionality of our website, including security features and load balancing. These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our website by collecting anonymized usage statistics. We may use services such as Google Analytics for this purpose.
• Functional Cookies: Remember your preferences and settings to provide a more personalized experience.

You can control cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. However, disabling certain cookies may affect the functionality of our website. For detailed instructions on managing cookies, please refer to your browser's help documentation.

3. How We Use Your Information

THR Guidance Inc. uses the personal information we collect for the following business purposes, all of which are necessary for providing our professional services and operating our business:

• To respond to your inquiries, provide quotes, and deliver the computer systems design, integration, and consulting services you have requested
• To communicate with you regarding project status, service updates, technical support, and account-related notifications
• To process payments and manage billing for services rendered
• To improve our website, services, and customer experience based on usage analytics and feedback
• To send marketing communications, newsletters, and promotional materials, subject to your consent where required by law
• To comply with legal obligations, enforce our Terms of Service, and protect our legal rights
• To detect, prevent, and investigate fraudulent activities, security incidents, and violations of our policies
• To maintain internal business records, conduct audits, and fulfill regulatory reporting requirements
• To evaluate and improve our service offerings, develop new solutions, and conduct market research

We will not use your personal information for purposes other than those described in this Privacy Policy unless we obtain your consent or are required by law to do so.

4. Legal Basis for Processing

Our legal basis for collecting and processing your personal information depends on the nature of the data and the context in which we collect it. We process personal information under the following legal grounds:

• Consent: Where you have given clear and explicit consent for us to process your personal information for a specific purpose, such as subscribing to marketing communications.
• Contractual Necessity: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract, such as preparing a service proposal.
• Legitimate Interests: Where processing is necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your data protection rights. This includes improving our services, ensuring network security, and preventing fraud.
• Legal Obligation: Where processing is necessary to comply with applicable laws, regulations, legal processes, or governmental requests.

5. Data Sharing and Disclosure

THR Guidance Inc. does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your personal information in the following limited circumstances:

5.1 Service Providers and Business Partners

We may engage trusted third-party service providers to perform functions on our behalf, such as website hosting, email delivery, payment processing, cloud infrastructure management, data analytics, and customer relationship management. These providers are contractually obligated to protect your data and use it only for the specific services we have engaged them to perform. They are not authorized to use your data for their own purposes.

5.2 Legal Compliance and Protection

We may disclose personal information when we believe in good faith that such disclosure is necessary to comply with applicable laws, regulations, court orders, subpoenas, or other legal processes, to enforce our Terms of Service and other agreements, to protect our rights, property, or safety and that of our employees, clients, or the public, and to respond to lawful requests from government authorities.

5.3 Business Transfers

If THR Guidance Inc. is involved in a merger, acquisition, asset sale, or other corporate reorganization, your personal information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

5.4 With Your Consent

We may share your personal information with third parties when we have obtained your explicit consent to do so, for purposes clearly identified at the time of requesting your consent.

6. Data Security

THR Guidance Inc. implements and maintains appropriate technical, administrative, and physical security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Industry-standard encryption protocols for data transmission, including TLS 1.3 for all web-based communications
• Secure server infrastructure with firewalls, intrusion detection systems, and regular vulnerability assessments
• Strict access controls and authentication mechanisms, including multi-factor authentication for administrative systems
• Regular security audits and penetration testing conducted by qualified third-party security professionals
• Employee training programs on data privacy, confidentiality obligations, and security best practices
• Data minimization practices ensuring we collect only what is necessary for the stated purposes
• Secure backup and disaster recovery procedures to ensure data availability and integrity

While we strive to protect your personal information using commercially reasonable means, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, and you acknowledge that you provide personal information at your own risk.

7. Data Retention

We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. The specific retention period varies depending on the type of data and the purpose of processing:

• Contact form submissions and inquiry records: Retained for up to 3 years from the date of last communication unless a longer period is required for ongoing business relationships
• Client account and billing information: Retained for the duration of the business relationship plus an additional 7 years to comply with Canadian tax and accounting regulations
• Website analytics data: Retained in aggregated form for up to 26 months, after which individual session data is anonymized or deleted
• Marketing communications consent records: Retained for as long as we send marketing communications plus evidence of consent for a reasonable period thereafter
• Legal and regulatory records: Retained as required by applicable laws governing our industry and jurisdiction

When personal information is no longer needed, we securely dispose of or anonymize the data using industry-standard methods.

8. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information. These rights may include:

8.1 Access and Portability

You have the right to request access to the personal information we hold about you and to receive a copy in a commonly used electronic format. We will respond to access requests within 30 days as required by Canadian privacy law.

8.2 Correction and Rectification

If you believe that any personal information we hold about you is inaccurate, incomplete, or outdated, you may request that we correct or update that information. We will make reasonable efforts to process such requests promptly.

8.3 Deletion

You may request that we delete your personal information, subject to certain exceptions where retention is required by law or necessary for the establishment, exercise, or defense of legal claims.

8.4 Withdrawal of Consent

Where we process your personal information based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To withdraw consent for marketing communications, you can use the unsubscribe link in any marketing email or contact us directly.

8.5 Opt-Out of Marketing

You may opt out of receiving marketing communications from us at any time by clicking the unsubscribe link in our emails, by emailing us at service@thrguidance.mom with the subject line Unsubscribe, or by calling +1 (754) 777-4920. Please note that even if you opt out of marketing, we may still send you transactional or service-related communications necessary for your account or ongoing services.

8.6 Complaints

If you have concerns about how we handle your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner. We encourage you to contact us first so we can address your concerns directly.

9. Children's Privacy

Our website and services are not directed to individuals under the age of 16. We do not knowingly collect, use, or disclose personal information from children under 16 years of age. If we become aware that we have inadvertently collected personal information from a child under 16 without verified parental consent, we will take immediate steps to delete that information from our records. If you believe that a child under 16 has provided us with personal information, please contact us at service@thrguidance.mom so we can investigate and take appropriate action.

10. International Data Transfers

THR Guidance Inc. is headquartered in Canada, and your personal information is primarily stored and processed on servers located in Canada. However, some of our service providers may be located in other countries, including the United States, and your information may be transferred to, stored, or processed in jurisdictions outside of Canada.

When we transfer personal information across borders, we take appropriate safeguards to ensure that your data receives a level of protection comparable to Canadian privacy standards. These safeguards may include contractual clauses, data processing agreements, and verification that the recipient jurisdiction maintains adequate data protection standards. By using our website and services, you acknowledge that your information may be transferred to and processed in countries other than your country of residence.

11. Third-Party Links and Services

Our website may contain links to third-party websites, applications, or services that are not operated or controlled by THR Guidance Inc. This Privacy Policy does not apply to any third-party services. We are not responsible for the privacy practices, content, or security of any third-party websites. We encourage you to review the privacy policies of any third-party services before providing them with your personal information.

12. Changes to This Privacy Policy

THR Guidance Inc. reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will post the revised Privacy Policy on this page with an updated last revised date and, where appropriate, provide additional notice through our website or via email.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information. Your continued use of our website and services after any changes become effective constitutes your acknowledgment and acceptance of the updated Privacy Policy. If you do not agree with the revised terms, you should discontinue using our website and services.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, or if you wish to exercise any of your privacy rights, please contact us using the details below. We are committed to addressing your inquiries promptly and thoroughly.

Privacy Commissioner Contact: If you are not satisfied with our response to your privacy concern, you may contact the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec K1A 1H3, or visit www.priv.gc.ca for more information.